DRC-2010-002649 - 0901a068801772e7

DENISON
MINES
^^^^^-^\0-CCDu4^
Denison Mines (USA) Corp.
1050 17th Streel, Suile 950
Denver, CO 80265
USA
Tel: [phone]
Fax : [phone]
www.denisonmines.com
.March 12,2010
VL\ OVERNKiHI DKLIVKRY AND F-MAU.
Mr. Dane L. i-incrlVock
C'u-Exccutive Secreiary
llt.ih Water Qualily Board
Depanment of Environniental Qual'ily
168 North 1950 Wcsl
P.O. Box 144810
Salt Lake Cily. tUali 8-11 14-4810
Re: Denison Mines (USA) Corp. White Me.sa Uranium Mill, (irouiuhvatcr Discharge
Permii No. UGVV370004 (the "GWDP") -Request for Information Regarding Ne«
Decontamination Pad and Submittal of Documents under Part 1.H.4 and I.H.5 of the
(;\VDP
Dear Mr. Finerfrock:
Denison Mines (l"SA) Corp. ("Denison"') is pioviding lhe follow responses to the February 4.
2009 Request for Infonnalion from ihc Divisitm of Radialion Conlrol ("DRC"). which DcnistMi
received on Febmary 12. 2010. Eacli DRC request is siiown in italics liclow. followed by
Denison's response lo llic ciiiestion and/or requcsi for infonnalion. in addition, this leller and ils
atlacliincnls are also inlcndcd lo satisfy ceriain rci|uircnicnts set oiil in F^iits I.ii.4(a) and I.II..'i(a)
and (b) of the GWDP.
I. RESPONSE TO REQUEST FOR IMORMATION
,4. DRC proposed inod'ificat'iona to paroiiraph r) in Aliochmciiis -Proposed Modificcilions to
tiie DMT Plan found in the Iclter dated .Iinn' 2^, 2009 hy Denison Mines lUS.Al Corp.:
I .Modify the Doily Inspeelinn fonn ifound in Section VII) fo include a location on theJoriii
to record the daily wafer level I depth} inspection information for pre.'^ence oJ Jlitid in all
leak deiection system (LDS) vertical inspection porteds for eoch of lhe three chanihers in
tlie concrete setllinfi lank system for liie deconlatninalion pad. Said inspeclion will he
made hy physically itieastihnii the depth to water with an eleclriml soiindini; tape/device.
Waler level depths will he recorded to the nearest O.OI fool.
OENISOJ)~~
MINES
March 12,2010
VIA OVERNIGHT DELIVERY AND E-MAIL
Mr.Dane L.Finerfrock
Co-Executive Secretary
Utah Water Quality Board
Department of Environmental Quality
168 North 1950 West
P.O.Box 144810
Sal'Lake City,Utah 84114-4810
Denison Mines (USA)Corp.
1050 17th Street,Suite 950
DenYef.CO 80265
USA
Tel:[phone]ma
Fill:303 389-4125
w_.denlsonmines.com
Re:Denison Mines (USA)Corp.White Mesa Uranium Mill,Groundwater Discharge
Permit No.UGW370004 (the "GWDP")-Request for Information Regarding New
Decontamination Pad and Submittal of Documents under Part 1.8.4 and I.H.5 of the
GWDP
Dear Mr.Finerfrock:
Denison Mines (USA)Corp.("Denison")is providing the follow responses to the February 4,
2009 Request for Information from the Division of Radiation Control ("DRe"),which Denison
received on February 12,2010.Each DRe request is shown in italics below,followed by
Denison's response to the question and/or request for information.In addiLion,this letter and its
attachments are also intended to satisfy certain requirements set out in Parts I.H.4(a)and I.H.5(a)
and (b)of the GWDP.
I.RESPONSE TO REQUEST FOR INFORMATION
A.DRC proposed modifications to paragraph r)in Attachments ~Proposed Modifications to
the DMT Planfoltnd in the letter dated JUlie 29,2009 by Denison Mines (USA)Corp.:
I Modify the Daily Inspection Fonn (found in Section VII)to include a location on theJonll
to record the daily water level (depth)inspection inJormation Jor presence ojfluid in all
leak detection system (LOS)vertical inspection ponalsJor each o/the three chambers in
the concrete settling tank system Jor the decontamination pad.Said inspection will be
made by physically measuring the depth to water with an electrical sounding tape/device.
Water level depths will be recorded to the nearest 0.01 Joot.
leiter 10 Dane L.Finerfrock
March 12,2010
Page 2
2 0"a quarterly basis submit with the DMT Perfonllance Standard Monitoring Report (I
summary of the daily water level (depth)inspections for the quarter for the presence of
fluid in all LDS vertical inspection portalsfor each ofthe three chambers in the concrete
settling tank system for the decontamination pad.The report will also include an
electronic or hard copy of daily inspection forms for the quarter and reporting of any
BATfailures for the decolltamillation pad.
3.Please revise the DMT/BAT Monitorillg Plan to include a peiformallce standard for
depth to water in the above mentiolled observation pipes,such thaI the waler level shall
1101 exceed a deplh equivalelll to O.I foot above the concrete floor at any lime.
4.Please provide a revised copy ofthe DMT/BAT Monitoring Plall in ils elllirety,for
review and approVlII
Denison Response:
Included as Attachment A to this letter is the draft White Mesa Mill Tailings Management System
and Discharge Minimization Technology (DMT)Monitoring Plan,3/10 Revision:Oenison-9 (the
"OMT Plan").The OMT Plan incorporates the foregoing requirements,as such requirements
were modified by correspondence dated March 10,2010 from ORe staff,as well as the
requirements set oul in Part I.H.4 of the GWDP.The attached DMT Plan is marked to indicate
changes over the previous draft submitted to ORC.
Also,included as Attachment B to this letter,for Executive Secretary Review and Approval,is
the draft White Mesa Uranium Mill COlllil/gency Plall,3.10 Revision:DUSA-2 (the
"Contingency Plan"),which incorporates the requirements of ParI I.H.4.(2)of the GWDP.The
attached Contingency Plan is marked 10 indicate changes over the previous draft submitted to
DRC.
B.Regarding Design issues:
4.No Comment.
5.Penneability oUhe CST Concrete.The estimated permeability values shown appear to be
in error.The range ofpenneabilities provided all appear to be too high.For example,
the penneobility provided using a 28-day concrete cure time is lxI07 ,,?This vallie
appears to correspond to a permeability.ofabo/lt 75 cm/sec.That penneability vallie
corresponds to very permeable gravel or coarse sOlld.which is not all approvable vallie.
An approvable estimate for the concrete permeability needs to correspond to the aclllal
OENISOJ)~~
MINES
Letter to Dane L.Finerfrock
March 12.2010
Page 3
estimated curing time.Permeability of concrete provided by the Engineering Toolbox
shows a typical permeability,10k,"of normal strength Portland cement concrete to be
abOIl1 Ix 10-10 cm/second,with k given in IIllits of velocity.This vallie for k is per the
equation v =k·i ,as provided by Corbitt
A revised permeability estimate needs to be submitted.Please include the estimated time
for curing ofthe concrete,corresponding to the revised permeability vallie.
Denison Response
A revised concrete mix assessment and penneability estimate prepared by Precision Systems
Engineering is included as Attachment C.The report estimates the penneability for cure times
ranging from 7 days to 10 years.
6.The As-Built Drawillgs.The DUSA letter ofNovember 16.2009 states,"Please see the
attached revised as-Imilt drawings,which indicate the as-bllilt elevatiolls and grades of
the concrete floors {//ul elevations ofthe walls ofthe Concrete Settling Tank (CST)."
No elevations (Jamsl)are given 011 the drawings provided.Please provide all current
changes to the drawings,including the elevations requested in the paragraph above.For
the observation ports the survey elevations should include elevations ofthe concrete floor
surface directly below the monitoring ports,allli the elevation of the top of the access
pipes (cap removed).Please label a complete set ofthe drawings "as-buill,"Gnd submit
for review and approval.
Denison Response:
A complete set of revised drawings is included as Attachment D,with the requested elevations
added,and stamped "As Built -Submitted for Review and Approval".
7.Location of the CST Leakage Monitoring Pipes./t appears the CST monitoring ports
have IIot changed location,per the submitted drawings.Please confirm that the CST
floor isflat.
Denison Response:
The concrete floor in the bottom of all three CST compartments is flat.
8.No Comment.
OENISOJ)JJ
MINES
Letter to Dane L.Finerfrock
March 12,2010
Page 4
9.No Comment.
10.No Comment.
1I./11 the DUSA fetter ojNovember 16,2009 it is stated that "DUSA intends to perform a
hydrostatic test [Oil the steel liner}commencing on December 1,2009."
Please provide DRC the results oj this testing,and ensure they (Ire certified by a Utah
licemed ProJessional Engineer.
Denison Response:
A copy of the latest hydrostatic test of the CST containments is included as Attachment E and is
certified by a State of Utah Registered Professional Engineer.
We are hopeful that this information and the enclosed attachments satisfy the DRC Request for
Information.We would like to begin using the new decontamination pad beginning Monday,
March 2200.Please advise if this is not acceptable.
2.PARTS I.H.4 AND I.H.S OF THE GWDP
Part I.H.4 of the GWDP requires thaI within 30 days of issuance of the revised GWDP,Denison
will submit an updated DMT Plan and Contingency Plan that reflect the requirements of Part
I.HA of the GWDP.The revised DMT Plan and Contingency Plan are included as Allachments
A and B to this letter.
Similarly,Part I.H.5 of the GWDP requires that within 30 days of issuance of the revised
GWDP,Denison will sub mil an updated DMT Plan that reflects the requirements of Part I.H.5 of
the GWDP,along with as built drawings of the Exisling Decontamination Pad.The revised
DMT Plan is included as Attachment A to this letter.The as built drawings of the Existing
Decontamination Pad are included as Attachment F to this letter.
Proposed revisions to the DMT Plan to address the New Decol1lamination Pad were submitted to
DRC on June 29,2009 and November 16,2009 and have been under discussion with DRC,
culminating in DRC's February 4,2010 Request for lnfonnation,which Denison received on
February 12,2010.As the resolution of the revisions to the DMT Plan for the New
Decontamination Pad are relevant to the revisions to the Contingency Plan for the New
Decontamination Pad and to the revisions to the DMT Plan for the Existing Decontamination
Pad,the submittals required under Parts I.H.4 and I.H.5 have been submillcd togelher with the
OENISOJ)~~
MINES
leiter to Dane L.Finerfrock
March 12,2010
PageS
other materials in response to and within 30 days of receipt of the February 4,20 I0 Request for
Information.This has resulted in the 30 day submittal periods specified in Parts I.HA and I.H.5
of the GWDP being exceeded by a few days.
If you have any questions on the attached information and documents please feel free to contact
me at [phone].
y,
ydenlund
Vice President,Regulatory Affairs and Counsel
Yours very t
DIIe.
Enclosures
cc:Ron F.Hochstein,wI attachment
Harold R.Roberts,wI attachment
10 Ann S.Tischler,w/attachmenl
Rich E.Bartlett,wI attachment
David E.Turk,wlo attachment
OENISOJ)~~
MINES
Attachment A
White Mesa Mill Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
S3/091Q Revision:Denison-82
Page 1 of 46
WHITE MESA MILL TAILINGS MANAGEMENT SYSTEM
AND
DISCHARGE MINIMIZATION TECHNOLOGY (DMT)
MONITORING PLAN
1.INTRODUCTION
This Tailings Management System and Discharge Minimization Technology Monitoring Plan (the
"Plan")for the White Mesa Mill (the "Mill")provides procedures for monitoring ofthe tailings cell
system as required under State of Utah Radioactive Materials License No.UT1900479 (the
"Radioactive Materials License"),as well as procedures for operating and maintenance ofmonitoring
equipment and reporting procedures that are adequate to demonstrate DMT compliance under State
of Utah Ground Water Discharge Permit No.370004 for the Mill (the "GWDP").
This Plan is designed as a systematic program for constant surveillance and documentation of the
integrity of the tailings impoundment system including dike stability,liner integrity,and transport
systems,as well as monitoring of water levels in Roberts Pond and feedstock storage areas at the
Mill.The Plan requires daily,weekly,quarterly,monthly and annual inspections and evaluations and
monthly reporting to Mill management.
2.DAILY TAILINGS INSPECTIONS
The following daily tailings inspections shall be performed:
2.1.Daily Comprehensive Tailings Inspection
On a daily basis,including weekends,all areas connected with the four tailings cells will be
inspected.Observations will be made of the current condition of each cell,noting any corrective
action that needs to be taken.
The Environmental or Radiation Technician is responsible for performing the daily tailings
inspections,except on weekends when the Shift Foreman will perform the weekend tailings
inspections.The Radiation Safety Officer may designate other individuals with training,as
described in Section 2.4 below,to perform the daily tailings inspection.
Observations made by the inspector will be recorded on the Daily Inspection Data form (a copy of
which is attached in Appendix A).The Daily Inspection Data form contains an inspection checklist,
which includes a tailings cells map,and spaces to record observations,especially those ofimmediate
White Mesa Mill -Standard Operating Procedures
Book II:Environmental Protection Manual,Section 3.1
Revision:Denison-&2
Page 2 of46
concern and those requiring corrective action.The inspector will place a check by all inspection
items that appear to be operating properly.Those items where conditions ofpotential concern are
observed should be marked with an "X".A note should accompany the "X"specifying what the
concern is and what corrective measures will resolve the problem.This observation of concern
should be noted on the form until the problem has been remedied.The date that corrective action
was taken should be noted as well.
Areas to be inspected include the following:CellI,2,3,and 4A,Dikes 1,2,3,4A-S,and 4A-W,
wind movement oftailings,effectiveness of dust minimization methods,spray evaporation,Cell 2
spillway,Cell 3 spillway,Cell 3 and 4A liquid pools and associated liquid return equipment,cell
leak detection systems,and the wildlife ponds.
Operational features of the tailings area are checked for conditions ofpotential concern.The
following items require visual inspection during the daily tailings inspection:
a)Tailings slurry and SX raffinate transport systems from the Mill to the active
disposal cell(s),and pool return pipeline and pumps.
Daily inspections ofthe tailings lines are required to be performed when the Mill
is operating.The lines to be inspected include the:tailings slurry lines from CCD
to the active tailings cell;SX raffinate lines that can discharge into CellI,Cell 3
or Cell 4A;the pond return line from the tailings area to the Mill;and,lines
transporting pond solutions from one cell to another.
b)CellI.
c)Cell 2.
d)Cell 3.
e)Ce1l4A.
f)Dike structures including dikes 1,2,3,4A-S,and 4A-W.
g)The Cell 2 spillway,Cell 3 spillway,Cell 3 and Cell 4A liquid pools and
associated liquid return equipment.
h)Presence of wildlife and/or domesticated animals in the tailings area,including
waterfowl and burrowing animal habitations.
i)Spray evaporation pumps and lines.
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
Revision:Denison-&.2
Page 301'46
j)Wind movement of tailings and dust minimization.
Wind movement of tailings will be evaluated for conditions which may require
initiation ofpreventative dust minimization measures for cells containing tailings
sand.During tailings inspection,general surface conditions will be evaluated for
the following:1)areas oftailings subject to blowing and/or wind movement,2)
liquid pool size,3)areas not subject to blowing and/or wind movement,
expressed as a percentage ofthe total cell area.The evaluations will be reviewed
on a weekly basis,or more frequently ifwarranted,and will be used to direct dust
minimization activities.
k)Observation offlow and operational status ofthe dust control/spray evaporation
system(s).
1)Observations of any abnormal variations in tailings pond elevations in Cells 1,3,
and 4A.
m)Locations of slurry and SX discharge within the active cells.Slurry and SX
discharge points need to be indicated on the tailings cells map included in the
Daily Inspection Data form.
n)An estimate of flow for active tailings slurry and SX line(s).
0)An estimate of flow in the solution return line(s).
p)Daily measurements in the leak detection system (LDS)sumps of the tailings
cells will be made when warranted by changes in the solution level of the
respective leak detection system.
The trigger for further action when evaluating the measurements in the CellI and
Cell 3 leak detection systems is a gain of more than 12 inches in 24 hours.The
solution level in Cell 4A leak detection is not allowed to be more than 1.0 foot
above the lowestpoint on the bottom flexible membrane liner (elevation 5556.14
feet amsl).If any of these observations are made,the Mill Manager should be
notified immediately and the leak detection system pump started.
Whenever the leak detection system pump is operating and the flow meter
totalizer is recording,a notation ofthe date and the time will be recorded on the
Daily Inspection Data form.This data will be used in accordance with License
Condition 11.3.B through 11.3.E ofthe Mill's Radioactive Materials License,to
determine whether or not the flow rate into the leak detection system is in excess
of the License Conditions.
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
Revision:Denison-g2
Page 4 of 46
q)An estimate ofthe percentage ofthe tailings beach surface area and solution pool
area is made,including estimates ofsolutions,cover areas,and tailings sands for
Cells 3 and 4A.
Items (a),(m),(n),and (0)are to be done only when the Mill is operating.When the Mill is down,
these items cannot be performed.
2.2.Daily Operations Inspection
During Mill operation,the Shift Foreman,or other person with the training specified in Section 2.4
below,designated by the Radiation Safety Officer,will perform an inspection ofthe tailings line and
tailings area at least once per shift,paying close attention for potential leaks and to the discharges
from the pipelines.Observations by the Inspector will be recorded on the appropriate line on the
Operating Foreman's Daily Inspection form.
2.3.Daily Operations Patrol
In addition to the inspections described in Sections 2.1 and 2.2 above,a Mill employee will patrol
the tailings area at least twice per shift during Mill operations to ensure that there are no obvious
safety or operational issues,such as leaking pipes or unusual wildlife activity or incidences.
No record ofthese patrols need be made,but the inspectors will notify the Radiation Safety Officer
and/or Mill management in the event that during their inspection they discover that an abnormal
condition or tailings emergency has occurred.
2.4.Training
All individuals performing inspections described in Sections 2.1 and 2.2 above must have Tailings
Management System training as set out in the Tailings Inspection Training procedure,which is
attached as Appendix B.This training will include a training pack explaining the procedure for
performing the inspection and addressing inspection items to be observed.In addition,each
individual,after reviewing the training pack,will sign a certification form,indicating that training
has been received relative to hislher duties as an inspector.
2.5.Tailings Emergencies
Inspectors will notify the Radiation Safety Officer and/or Mill management immediately if,during
their inspection,they discover that an abnormal condition exists or an event has occurred that could
cause a tailings emergency.Until relieved by the Environmental or Radiation Technician or
Radiation Safety Officer,inspectors will have the authority to direct resources during tailings
emergencIes.
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
Revision:Denison-&2
Page 5 of46
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediately to the Mill Manager or theRadiation Safety Officer,one ofwhom will notifyCorporate
Management.If dam failure occurs,notify your supervisor and the Mill Manager immediately.The
Mill Manager will then notify Corporate Management,MSHA (303-231-5465),and the State of
Utah,Division ofDam Safety (801-538-7200).
3.WEEKLY TAILINGS AND DMT INSPECTION AND WEEKLY AND MONTHLY
SURVEYS
3.1.Weekly Tailings Inspections
Weekly tailings inspections are to be conducted bythe Radiation SafetyDepartment and include the
following:
a)Leak Detection Systems
Each tailings cell's leak detection system shall be checked weekly to determine
whether it is wet or dry.Ifmarked wet,the liquid levels need to be measured and
reported.In Cell 1 and Cell 3 the leak detection system is measured by use of a
pipe that is removed from the system which will indicate the presence of
solutions in the LDS system.The Cell4A leak detection system is monitored on
a continuous basis by use of a pressure transducer that feeds water level
information to an electronic data collector.The pressure transducer is calibrated
for fluid with a specific gravity of 1.0.The water levels are measured every hour
and the information is stored for later retrieval.The water levels are measured to
the nearest 0.10 inch.The data collector is currently programmed to store 7 days
of water level information.The number of days ofstored data can be increased
beyond 7 days if needed.The water level data is downloaded to a laptop
computer on a weekly basis and incorporated into the Mill's environmental
monitoring data base,and into the files for weekly inspection reports of the
tailings cell leak detection systems
If sufficient fluid is present in the leak detection system ofany cell,the fluid shall
be pumped from the LDS,to the extent reasonably possible,and record the
volume offluid recovered.Any fluid pumped from an LDA shall be returned to a
disposal cell.
If fluid is pumped from an LDS,the flow rate shall be calculated by dividing the
recorded volume of fluid recovered by the elapsed time since fluid was last
pumped or increases in the LDS fluid levels were recorded,whichever is the
more recent.This calculation shall be documented as part of the weekly
White Mesa Mill -Standard Operating Procedures
Book II:Environmental Protection Manual,Section 3.1
inspection.
Revision:Denison-8-2
Page 6 of46
Upon the initial pumping offluid from an LDS,a fluid sample shall be collected
and analyzed in accordance with paragraph 11.3 C.of the Radioactive Materials
License.
For CeIl4A,under no circumstance shall fluid head in the leak detection
system sump exceed a I-foot level above the lowest point in the lower flexible
membrane liner.To determine the Maximum Allowable Daily LDS Flow
Rates in the Cell 4A leak detection system,the total volume of all fluids
pumped from the LDS on a weekly basis shall be recovered from the data
collector,and that information will be used to calculate an average volume
pumped per day.Under no circumstances shall the daily LDS flow volume
exceed 24,160 gallons/day.The maximum daily LDS flow volume will be
compared against the measured cell solution levels detailed on Table 1 in
Appendix E,to determine the maximum daily allowable LDS flow volume for
varying head conditions in Ce1l4A.
b)Slimes Drain Water Level Monitoring
(i)Cell 3 is an active tailings cell while Cell 2 is partially reclaimed with approximately
90%of the surface covered by platform fill.Each cell has a slimes drain system
which aids in dewatering the slimes and sands placed in the cell;
(ii)Cell 2 has a pump placed inside of the slimes drain access pipe at the bottom of the
slimes drain.As taken from actual measurements,the bottom of the slimes drain is
38 feet below a water level measuring point at the centerline of the slimes drain
access pipe,at the ground surface level.This means that the bottom of the slimes
drain pool and the location of the pump are one foot above the lowest point of the
FML in Cell 2,which,based on construction reports,is at a depth of 39 feet below
the water level measuring point on the slimes drain access pipe for Cell 2;
(iii)The slimes drain pump in Cell 2 is on a timed system,under which it pumps for 15
minutes each hour,thereby allowing the slimes wastewater to recharge for 45
minutes before being pumped again.Based on measurements taken in August 2006,
the water level in the Cell 2 slimes drain recharges to a depth of about 28.50 feet
before each pumping and is pumped to a depth of38 feet after each pumping,in each
case measured below the water level measuring pointonthe slimes drain access pipe.
The average wastewater head in the Cell 2 slimes drain is therefore about 5 feet.The
depth to water of about 28.50 feet after recharge is below the phreatic surface of
tailings Cell 2,which is at a depth of about 20 feet below the water level measuring
point on the slimes drain access pipe.As a result,there is a continuous flow of
wastewater from Cell 2 into the slimes drain collection system.Mill management
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
Revision:Denison-&;>
Page 7 of46
considers that the average allowable wastewater head in the Cell 2 slimes drain
resulting from pumping at these intervals is satisfactory and is as low as reasonably
achievable.Based on past experience,cycling the pump more than 15 minutes every
hour can result in more replacement costs for pumps and more resulting system
downtime;
(iv)The Cell 2 slimes drain pump is checked weekly to observe that it is operating and
that the timer is set properly,which is noted on the Weekly Tailings Inspection Form.
If at any time the pump is observed to be not working properly,it will be fixed or
replaced within 15 days;
(v)Depth to wastewater in the Cell 2 slimes drain access pipe shall be monitored and
recorded weekly to determine maximum and minimum fluid head before and after a
pumping cycle,respectively.All head measurements must be made from the same
measuring point (the notch at the north side of the access pipe),and made to the
nearest 0.01 foot.The results will be recorded as depth-in-pipe measurements on the
Weekly Tailings Inspection Form;
(vi)On a monthly basis,the slimes drain pump will be turned off and the wastewater in
the slimes drain access pipe will be allowed to stabilize for at least 90 hours.Once
the water level has stabilized (based on no change in water level for three (3)
successive readings taken no less than one (1)hour apart)the water level of the
wastewater will be measured and recorded as a depth-in-pipe measurement on the
Monthly Inspection Data form,by measuring the depth to water below the water level
measuring point on the slimes drain access pipe;
(vii)No process liquids shall be allowed to be discharged into Cell 2;
(viii)If at any time the most recent average annual head in the Cell 2 slimes drain is
found to have increased above the average head for the previous calendar year,the
Licensee will comply with the requirements ofPmtLG.3 ofthe GWDP,including the
requirement to provide notification to the Executive Secretary orally within 24 hours
followed by written notification;
(ix)Because Cell 3 and Cell4A are currently active,no pumping from the Cell 3 or Cell
4A slimes drain is authorized.Prior to initiation oftailings dewatering operations for
Cell 3 or Cell 4A,a similar procedure will be developed for ensuring that average
head elevations in the Cell 3 and Cell4A slimes drains are kept as low as reasonably
achievable,and that the Cell 3 and Cell4A slimes drains are inspected and the results
reported in accordance with the requirements ofthe permit."
c)Wind Movement ofTailings
An evaluation of wind movement of tailings or dusting and control measures
shall be taken if needed.
d)Tailings Wastewater Pool and Beach Area Elevation Monitoring
White Mesa Mill Standard Operating Procedures
Book II:Environmental Protection Manual,Section 3.1
Revision:Denison-82
Page 8 of46
Solution elevation measurements in Cells 1 and 4A and Roberts Pond are to be taken by
survey on a weekly basis,and the beach area in Ce1l4A with the maximum elevation is to
be taken by survey on a monthly basis,as follows:
(i)The survey will be performed by the Mill's Radiation Safety Officer or designee
(the "Surveyor")with the assistance of another Mill worker (the "Assistant");
(ii)The survey will be performed using a survey instrument (the "Survey Instrument")
accurate to 0.01 feet,such as a Sokkai No.B21,or equivalent,together with a
survey rod (the "Survey Rod")having a visible scale in 0.01 foot increments;
(iii)The reference Points (the "Reference Points")for Cells 1 and 4A,and Roberts
Pond are known points established by professional survey.For Cell 1 and Roberts
Pond,the Reference Point is a wooden stake with a metal disk on it located on the
southeast corner of Cell 1.The elevation of the metal disk (the "Reference Point
Elevation")for Cell 1 and Roberts Pond is at 5,623.14 feet above mean sea level
("FMSL").For Cell 4A,the Reference Point is a piece of metal rebar located on
the south dike of Cell 3.The elevation at the top of this piece of rebar (the
Reference Point Elevation for Cell 4A)is at 5,607.83 FMSL;
(iv)The Surveyor will set up the Survey Instrument in a location where both the
applicable Reference Point and pond or beach surface are visible.For Cell 1 and
Roberts Pond,this is typically on the road on the Cell 1 south dike between Cell 1
and Roberts Pond,approximately 100 feet east of the Cell l/Roberts Pond
Reference Point.For Cell 4A,this is typically on the road on the Cell 3 dike
approximately 100 feet east of the Cell 4A Reference Point;
(v)Once in location, the Surveyor will ensure that the Survey Instrument is level by
centering the bubble in the level gauge on the Survey Instrument;
(vi)The Assistant will place the Survey Rod vertically on the Reference Point (on the
metal disk on the Cell l/Roberts Pond Reference Point and on the top of the rebar
on the Cell 4A Reference Point.The Assistant will ensure that the Survey Rod is
vertical by gently rocking the rod back and forth until the Surveyor has established
a level reading;
(vii)The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod,and record the number (the "Reference Point Reading"),which
represents the number of feet the Survey Instrument is reading above the reference
Point;
(viii)The Assistant will then move to a designated location where the Survey Rod can
be placed on the surface of the main solution pond in Cell 1,Cell 4A or Roberts
Pond,or the area ofthe beach in Cell 4A with the highest elevation,as the case
may be.These designated locations,and the methods to be used by the Assistant
to consistently use the same locations are as follows:
A.Pond Surface Measurements
White Mesa Mill -Standard Operating Procedures
Book II:Envirorunental Protection Manual,Section 3.1
I.Ce1l4A
Revision:Denison-&2
Page 9 of 46
The Assistant will walk down the slope in the northeast corner of Cell 4A and
place the Survey Rod at the liquid level.
II.Cell 1
A mark has been painted on the north side of the ramp going to the pump
platform in Cell 1.The Assistant will place the Survey Rod against that mark
and hold the rod vertically,with one end just touching the liquid surface;and
III.Roberts Pond
A mark has been painted on the railing of the pump stand in Roberts Pond.The
Assistant will place the Survey Rod against that mark and hold the rod
vertically,with one end just touching the liquid surface.
Based on the foregoing methods,the approximate coordinate locations for the
measuring points for Roberts Pond and the Cell 1 and 4A pond surface are:
Northing Easting
Roberts Pond 323,041 2,579,697
CellI 322,196 2,579,277
Ce1l4A 320,300 2,579,360
These coordinate locations may vary somewhat depending on solution
elevations in the Pond and Cells;
B.Ce1l4A Beach Elevation
The Assistant will place the Survey Rod at the point on the beach area of Cell 4A
that has the highest elevation.If it is not clear which area ofthe beach has the
highest elevation,then multiple points on the beach area will be surveyed until the
Surveyor is satisfied that the point on the Cell 4A beach area with the highest
elevation has been surveyed.If it is clear that all points on the Cell 4A beach area
are below 5,593 FMSL,then the Surveyor may rely on one survey point;
(ix)The Assistant will hold the Survey Rod vertically with one end of the Survey Rod
just touching the pond or beach surface.The Assistant will ensure that the Survey
Rod is vertical by gently rocking the rod back and forth until the Surveyor has
established a level reading;
White Mesa Mill-Standard Operating Procedures
Book II:Environmental ProtCClion Manual,Section 3.1
~JI()l)lQ Revision:Denison-82
Page 10 of46
(x)The Surveyor will focus the cross hairs of the Survey Instrument on the scale on
the Survey Rod,and record the number (the "Surface Reading"),which represents
the number of feet the Survey Instrument is reading above the pond or beach
surface level.
The Surveyor will calculate the elevation of the pond or beach surface as FSML by adding
the Reference Point Reading for the Cell or Roberts Pond,as the case may be,to the
Reference Point Elevation for theCelioI'Roberts Pond and subtracting the Sutface Reading
for the Cell or Roberts Pond,and will record the number accurate to 0.0 I feet.
(')DecrJl/fflm;IUlliol1 Pads
(i)New DecolltamillaliOll Pad
The New Decontamination Pad is located in the southeast corner of the ore
pad,ncar the Mill's scale house.
A.In order to en~ure that the primary containment of the New
Decontamination Pad water collection ~yMem ha~not been
compromised.and to provide an inspection capability to detect
leakage from the primary containment.vertical inspection portal~
have been installed between the primary and secondary containment~:
B.These portal~will be visually ob~erved on a weckly basis as a mean.I,
ofdetecting any leakage from the primary containmcnt into the void
between the primary and secondary containment.The depth Lo water
in each pOt1al will bc measured weekly,by physically mea~uring the
depth to wHler with an electrical sounding tape/device.All
measurements must be made from the same measuring point and be
made to the nearest 0.0 I foot:
C.Thet;e inspections will be recorded on the WeeklyTailings Inspection
fonn:
D.The WaleI'level shall not cxceed 0.10 foot above thecol1crete floor in
any standpipe,at any time.Thi~will be detennined by subtracting the
wcekly depth to watcr measurement from the diswnce from the
measuring poim in the standpipe to the dry concrcte floor:
E.Any observation of fluid between the primary and sccondary
containments will be reported to the Radiation Safety Officer (RSO).
White Mesa Mill-Standard Operaling Procedures
Book II:Environmenlal Proleclion Manual,Seclion 3.1
~J.lQ9.ill Revision:Denison-&2
Page 11 of46
F,In addition to inspection of the water levels in the standpipes.the
New Decontamination Pad.including the concrete integrity of the
exposed surfaces of the pad.will be inspected on a weekly basis.
Observations will be made of the currenl condition of the New
Decol1laminntion Pad.Any abnormalities relating to the pad and any
damage to the concrete wash surface of the pad will be noted on the
Weekly Tailings Inspection fonn.If there are any cracks greater than
1/8 inch separation (width).the RSO must be contacted.The RSO
will have the responsibility to cease activities ond have the cracks
repaired.
(ijJ EAis/illg Decoll/WlIillatioll Pad
The Existing Decontamination Pad is located between the northwcst comcrorthe
Mill's maintenance shop and the ore feeding grizzly.
A.The Existing Decontamination Pad will be inspected on a weekly
basis.Observmions will be made of the current condition of the
Existing Decontamination Pad.including the concrete integrity ofthe
exposed surfaces of the pad.Any abnomlalitics relating to the pad
and any damage or erach on the concrete wash surface of the pad
will be noted on the Weekly Tailings Inspection rorm.If there are
any cracks greater than 1/8 inch separalion (width).the RSO must be
contacled.The RSO will have the responsibility to cease activities
and have the cracks repaired.
e-}f)Summary
In addition,the weekly inspection should summarizeall activities concerning the
tailings area for that particular week.
Results of the weekly tailings inspection are recorded on the Weekly Tailings and DMTInspection
fonn.An example ofthe Weekly Tailings and DMTInspeclion form is provided in Appendix A.
3.2.Weekly Inspection of Solution Levels in Roberts Pond
On a weekly basis,solution elevations are taken on Roberts Pond,in accordance with the procedures
set out in Section 3.1 d)above.The Weekly solution level in Roberts Pond is recorded on the
Weekly Tailings and DMT Inspeclioll form.Based on historical observations,the FML at the Pond
Surface Reading area for Roberts Pond,is approximately six inches above the lowest point on the
White Mesa Mill -Standard Operating Procedures
Book II:Environmental Protection Manual,Section 3.1
Revision:Denison-&.2
Page 12 of46
pond's FML.Ifthe pond solution elevation at the Pond Surface Reading area is at or below theFML
for that area,the pond will be recorded as being dry.
3.3.Weekly Feedstock Storage Area Inspections
Weekly feedstock storage area inspections will be performed by the Radiation Safety Department,
confirm that:
a)the bulk feedstock materials are stored and maintained within the defined area described in
the GWDP,as indicated on the map attached hereto as Appendix D;and
b)all alternate feedstock located outside the defined Feedstock Area are maintained within
water tight containers.
The results ofthis inspection will be recorded on the Ore Storage/Sample Plant Weekly Inspection
Report,a copy of which is contained in Appendix A.Any variance in stored materials from this
requirement or observed leaking alternate feedstock drums or other containers will be brought to the
attention of Mill Management and rectified within 15 days.
4.MONTHLY TAILINGS INSPECTION
Monthly tailings inspections will be performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department and recorded on the Monthly Inspection Data form,an example of
which is contained inAppendix A.Monthly inspections are to be performed no sooner than 14 days
since the last monthly tailings inspection and can be conducted concurrently with the quarterly
tailings inspection when applicable.The following items are to be inspected:
a)Tailings Slurry Pipeline
When the Mill is operating,the slurry pipeline will be inspected at key locations to
determine pipe wear.Pipe thickness will be measured using an ultrasonic device by
either the radiation safety staffor other trained designees.The critical points of the
pipe include bends,slope changes,valves,and junctions,which are critical to dike
stability.These locations to be monitored will be determined by the Radiation Safety
Officer or his designee from the Radiation Safety Department during the Mill run.
b)Diversion Ditches
Diversion ditches 1,2 and 3 shall be monitored monthly for sloughing,erosion,
undesirable vegetation,and obstruction offlow.Diversion berm 2 should be checked
for stability and signs of distress.
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
c)Sedimentation Pond
Revision:Denison-&2
Page 13 of46
Activities around the Mill and facilities area sedimentationpond shall be summarized
for the month.
d)Overspray Dust Minimization
The inspection shall include an evaluation ofoverspray minimization,if applicable.
This entails ensuring that the overspray system is functioning properly.In the event
that overspray is carried more than 50 feet from the cell,the overspray system should
be immediately shut-off.
White Mesa Mill -Standard Operating Procedures
Book II:Environmental Protection Manual,Section 3.1
e)Remarks
Revision:Denison-g2
Page 14 of46
A section is included on the Monthly Inspection Data form for remarks in which
recommendations can be made or observations of concern can be documented.
f)Summary ofDaily,Weekly and Quarterly Inspections
The monthly inspection will also summarize the daily,weekly and,if applicable,
quarterly tailings inspections for the specific month.
In addition,settlement monitors are typically surveyed monthly and the results reported on the
Monthly Inspection Data form.
5.QUARTERLY TAILINGS INSPECTION
The quarterly tailings inspection is performed by the Radiation Safety Officer or his designee from
the Radiation Safety Department,having the training specified in Section 2.4 above,once per
calendar quarter.A quarterly inspection should be performed no sooner than 45 days since the
previous quarterly inspection was performed.
Each quarterly inspection shall include an Embankment Inspection,an Operations/Maintenance
Review,a Construction Review and a Summary,as follows:
a)Embankment Inspection
The Embankment inspection involves a visual inspection ofthe crest,slope and toe
of each dike for movement,seepage,severe erosion,subsidence,shrinkage cracks,
and exposed liner.
b)Operations/Maintenance Review
The Operations/Maintenance Review consists of reviewing Operations and
Maintenance activities pertaining to the tailings area on a quarterly basis.
c)Construction Review
The Construction Review consists of reviewing any construction changes or
modifications made to the tailings area on a quarterly basis.
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
d)Summary
Revision:Denison-&2
Page 15 of 46
The summary will include all major activities or observations noted around the
tailings area on a quarterly basis.
If any of these conditions are noted,the conditions and corrective measures taken should be
documented in the Quarterly Inspection Data form.An example of the Quarterly Inspection Data
form is provided in Appendix A.
6.ANNUAL EVALUATIONS
The following annual evaluations shall be performed:
6.1.Annual Technical Evaluation
An annual technical evaluation of the tailings management system is performed by a registered
professional engineer (PE),who has experience and training in the area of geotechnical aspects of
retention structures.The technical evaluation includes an on-site inspection of the tailings
management system and a thorough review of all tailings records for the past year.The Technical
Evaluation also includes a review and summary ofthe annual movement monitor survey (see Section
5.2 below).
All tailings cells and corresponding dikes will be inspected for signs of erosion,subsidence,
shrinkage,and seepage.The drainage ditches will be inspected to evaluate surface water control
structures.
In the event tailings capacity evaluations (as per SOP PBL-3)were performed for the receipt of
alternate feed material during the year,the capacity evaluation forms and associated calculation
sheets will be reviewed to ensure that the maximum tailings capacity estimate is accurate.The
amount oftailings added to the system since the last evaluation will also be calculated to determine
the estimated capacity at the time of the evaluation.
Tailings inspection records will consist ofdaily,weekly,monthly,and quarterly tailings inspections.
These inspection records will be evaluated to determine if any freeboard limits are being
approached.Records will also be reviewed to summarize observations of potential concern.The
evaluation also involves discussion with the Environmental and/or Radiation Technician and the
Radiation Safety Officer regarding activities around the tailings area for the past year.During the
annual inspection,photographs of the tailings area will be taken.The training ofindividuals will be
reviewed as a part ofthe Annual Technical Evaluation.
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
Revision:Denison-&2
Page 16 of 46
The registered engineer will obtain copies of selected tailings inspections,along with the monthly
and quarterly summaries of observations of concern and the corrective actions taken.These copies
will then be included in the Annual Technical Evaluation Report.
The Annual Technical Evaluation Report must be submitted by September 151 of every year to:
Directing Dam Safety Engineer
State ofUtah,Natural Resources
1636 West North Temple,Suite 220
Salt Lake City,Utah 84116-3156
6.2.Movement Monitors
A movement monitor survey is to be conducted by a licensed surveyor annually during the second
quarter ofeach year.The movement monitor survey consists ofsurveying monitors along dikes 3-S,
4A-W,and 4A-S to detect any possible settlement or movement of the dikes.The data generated
from this survey is reviewed and incorporated into the Annual Technical Evaluation Report of the
tailings management system.
6.3.Freeboard Limits
The freeboard limits set out in this Section are intended to capture the Local 6-hour Probable
Maximum Precipitation (PMP)event,which was determined in the January 10,1990 Drainage
Report (the "Drainage Report")for the White Mesa site to be 10 inches.
The flood volume from the PMP event over the Cell 1 pond area plus the adjacent drainage areas,
was calculated in the Drainage Report to be 103 acre feet of water,with a wave run up factor of
0.90 feet.
The flood volume from the PMP event over the Cell 2 and Cell 3 pond areas,plus the adjacent
drainage areas was calculated in the Drainage Report to be 123.4 acre-feet of water.
The flood volume from the PMP event over the Cell 4A area was calculated in the Drainage
Report to be 36 acre-feet of water (40 acres,plus the adjacent drainage area of 3.25 acres,times
the PMP of 10 inches),with a wave run up factor of0.77 feet.
The total pool surface area in Cell 1 is 52.9 acres and in Cell4A is 40 acres.The top of the
flexible membrane liner ("FML")for Cell 1 is 5,618.2 FMSL and for Cell4A is 5,598.5 FMSL.
Based on the foregoing,the freeboard limits for the Mill's tailings cells will be set as follows:
White Mesa Mill Standard Operating Procedures
Book I I:Environmental Protection Manual,Section 3.I
Revision:Denison-g2
Page 17 of 46
6.3.1.
The freeboard limit for CellI will be set at 5,615.4 FMSL.This will allow CellI to capture all of
the PMP volume associated with Cell 1.The total volume requirement for Cell 1 is 103 acre feet
divided by 52.9 acres equals 1.95 feet,plus the wave run up factor of0.90 feet equals 2.85 feet.The
freeboard limit is then 5,618.2 FMSL minus 2.85 feet equals 5,615.4 FMSL.Under Radioactive
Materials License condition 10.3,this freeboard limit is set and is not recalculated annually.
6.3.2.Cell 2
The freeboard limit for Cell 2 is inapplicable,since Cell 2 is filled with solids.All of the PMP
volume associated with Cell 2 will be attributed to Cell 4A (and/or any future tailings cells).
6.3.3.Cell 3
The freeboard limit for Cell 3 is inapplicable,since Cell 3 is close to being filled with solids,and all
of the PMP flood volume associated with Cell 3 will be attributed to Cell 4A (and/or any future
tailings cells).
6.3.4.Cell4A
The freeboard limit for Cell4A will be set assuming that the total PMP volume for Cells 2,3 and 4A
of 159.4 acre feet will be accommodated in Ce1l4A.The procedure for calculating the freeboard
limit for Cell 4A is as follows:
(a)When the Pool Suiface Area is 40 Acres
When the pool surface area in Cell 4A is 40 acres (i.e.,when there are no beaches),the freeboard
limit for Cell4A will be 5,593.7 FMSL,which is 4.76 feet below the FML (being the quotient of
159.4 acre feet divided by 40 acres,which equals 3.99 feet,plus the wave run up factor for Cell4A
of 0.77 feet,rounded to the nearest one-tenth of a foot);
(b)When the Maximum Elevation ofthe Beach Area is 5,593 FMSL or Less
When the maximum elevation ofthe beach area in Cell4A is 5593 FMSL or less,then the freeboard
limit will be 5,593.7 FMSL,which is the same as in (a)above.This allows for the situation where
there may be beaches,but these beaches are at a lower elevation than the freeboard limit established
in (a)above,and there is therefore ample freeboard above the beaches to hold the maximum PMP
volume.The maximum elevation of the beach area will be determined by monthly surveys
performed by Mill personnel in accordance with the Mill's DMT Plan.
(c)When the Maximum Elevation ofthe Beach Area First Exceeds 5,593 FMSL
When the maximum elevation of the beach area in Cell 4A first exceeds 5,593 FMSL,then the
freeboard limit for the remainder ofthe ensuing year (period t=O)(until the next November 1)will be
calculated when that elevation is first exceeded (the "Initial Calculation Date"),as follows:
White Mesa Mill -Standard Operating Procedures
Book II:Environmental Protection Manual,Section 3.1
Revision:Denison-&2
Page 18 of 46
i)The total number ofdry tons oftailings that have historically been deposited into Cell
4A prior to the Initial Calculation Date ("To")will be determined;
ii)The expected number ofdry tons to be deposited into Cell4Afor the remainder ofthe
ensuing year (up to the next November 1),based on production estimates for that
period ("~o*"),will be determined;
iii)~o*will be grossed up by a safety factor of 150%to allow for a potential
underestimation of the number of tons that will be deposited in the cell during the
remainder of the ensuing year.This grossed up number can be referred to as the
"modeled tonnage"for the period;
iv)The total design tailings solid storage capacity of Cell 4A will be accepted as
2,094,000 dry tons of tailings;
v)The available remaining space in Cell4A for solids as at the Initial Calculation Date
will be calculated as 2,094,000 dry tons minus To;
vi)The reduction in the pool surface area for the remainder of the ensuing year will be
assumed to be directly proportional to the reduction in the available space in Cell4A
for solids.That is,the reduced pool surface area for period t=O ("RPAo"),after the
reduction,will be calculated to be:
(1 -(~o*x 1.5)/(2,094,000 -To»x 40 acres =RPAo
vii)The required freeboard for Cell 4A for the remainder of the period t=O can be
calculated in feet to be the wave run up factor for Cell 4A of 0.77 feet plus the
quotient of 159.4 acre feet divided by the RPAo.The freeboard limit for Cell4A for
the remainder of period t=O would then be the elevation of the FML for Cell 4A of
5598.5 FMSL less this required freeboard amount,rounded to the nearest one-tenth of
a foot;and
viii)The foregoing calculations will be performed at the Initial Calculation Date and the
resulting freeboard limit will persist until the next November 1.
An example of this calculation is set out in Appendix F.
(d)Annual Freeboard Calculation When the Maximum Elevation ofthe BeachArea Exceeds
5,593 FMSL
On November 1 of each year (the "Annual Calculation Date"),the reduction in pool area for the
ensuing year (referred to as period t)will be calculated by:
i)First,calculating the Adjusted Reduced Pool Area for the previous period (ARPAt_I)
to reflect actual tonnages deposited in Cell 4A for the previous period (period t-1).
The RPAt-I used for the previous period was based on expected tonnages for period t-
1,grossed up by a safety factor.The ARPAt-I is merely the RPA that would have
been used for period t-1 had the actual tonnages for year t-1 been known at the outset
ofperiod t-1 and had the RPA been calculated based on the actual tonnages for period
t-1.This allows the freeboard calculations to be corrected each year to take into
account actual tonnages deposited in the cell as of the date of the calculation.The
ARPAt-Ican be calculated using the following formula:
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
(1-L1t-1 /(2,094,000 -Tt-I))X ARPAt_2 =ARPAt-1
Revision:Denison-&2
Page 19 of46
Where:
•L1t-1 is the actual number of dry tons of tailings solids deposited in Cell 4A
during period t-1 ;
• Tt-I is the actual number of dry tons of tailings solids historically deposited in
Ce1l4A prior to the beginning of period t-l;and
•ARPAt-2 is the Adjusted Reduced Pool Area for period t-2.If period t-2
started at the Initial Calculation Date,then ARPAt-2 is 40 acres;
ii)Once the ARPAt_1for the previous period (period t-l)has been calculated,the RPA
for the subject period (period t)can be calculated as follows:
(1 -(L1t*x 1.5)/(2,094,000 - Tt))x ARPAt_1 =RPAt
Where:
•L1t*is the expected number of dry tons oftailings to be deposited into Ce1l4A
for the ensuing year (period t),based on production estimates for the year (as
can be seen from the foregoing formula,this expected number is grossed up
by a safety factor of 1.5);
• Ttis the actual number of dry tons of tailings solids historically deposited in
Ce1l4A prior to the beginning of period t;and
•ARPAt_1is the Adjusted Reduced Pool Area for period t-l,which is the pool
surface area for the previous period (period t-l)that should have applied
during that period,had modeled tonnages (i.e.,expected tonnages grossed up
by the 150%safety factor)equaled actual tonnages for the period;
iii)The required freeboard for period t can be calculated in feet to be the wave run up
factor for Cell 4A of 0.77 feet plus the quotient of 159.4 acre feet divided by the
RPAt.The freeboard limit for Ce1l4A for period t would then be the elevation ofthe
FMLfor Ce1l4A of5598.5 FMSL less this required freeboard amount,rounded to the
nearest one-tenth of a foot;and
iv)The foregoing calculations will be performed at the Annual Calculation Date for
period t and the resulting freeboard limit will persist until the next Annual Calculation
Date for period t+1.
An example of this calculation is set out in Appendix F.
(e)When a Spillway is Added to Ce1l4A that Allows Overflow Into a New Tailings Cell
When a spillway is added between Ce1l4A and a new tailings cell (Ce1l4B),then,if an approved
freeboard limit calculation method for the new cell is set to cover the entire PMP event for Cells 2,3,
4A and 4B,the freeboard limit for Ce1l4A will be inapplicable,except for approved provisions to
prevent storm water runoff from overtopping dikes.
While Mesa Mill-Slandard Operaling Procedures
Book II:Environmental Proleclion Manual,Section 3.1
:SJ/Q9..!.Q Revision:Denison-&.2
Page 20 of46
6.3.5.Roberts Pond
The freeboard limit for Roberts Pond is a liquid maximum elevation of5,624.0 feet above mean sea
level,as specified in the GWDP.
6.4.Annual Leak Detection Fluid Samples
In the event solution has been detected in a leak detection system,a sample will be collected on an
annual basis.This sample will be analyzed according 10 the conditions set forth in License
Condition 11.3.e.The results of the analysis will be reviewed to dClcnnine the origin of the
solution.
6.5.Annual Inspection of the Decontamination Pad\
al New Decontamination Pad
During the second quarter of each year,the New Decontamination Pad will be taken out ofservice
and inspected to ensure the integrity of the wash pad's exposed concrete \urface.If any
abnomlalities,are identified.i.e.cracks in the concrete with greater than 1/8 inch !\cparation (width)
or any \ignificant deterioration or damage of the pad \urface.repairs will be made prior to resuming
the use ofthe facility.All inspection findings and any rcpairs required .l.hall be documented on the
Annual Decontamination Pad Il1.I.pection form.The in'ipeclion findings.any repairs required and
repair~completed shall be summarized in the 2"d Quarter DMT Monitoring Repon due September I
of each calendar year.
bl Exi!'.ting Decontamination Pad
During the second quarter of each year,thc Existing Decontamination Pad will be taken out of
service and inspected to ensure the integrity of the steel tank.If any abnonnalities are identified.
repairs will be made prior to resuming the use of(he facility.All inspection findings and any repairs
required shall be documented on the Annual Decontamination Pad Inspection fonn.The inspeclion
findings.any repaifll re«(Hired and repairs completed ~hall be summarized in the 2nd Quarter DMT
Monitorin2.Repon due September I ofeach calendar year.
7.OTHER INSPECTIONS
All daily,weekly,monthly,quarterly and annual inspections and evaluations should be performed as
specified in Sections 2,3,4,5 and 6 above.However,additional inspections should be conducted
after any significant storm or significant natural or man-made event occurs.
8.REPORTING REQUIREMENTS
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
Revision:Denison-&2
Page 21 of46
In addition to the Daily Inspection Data,Weekly Tailings Inspection,Monthly Inspection Data and
Quarterly Inspection Data forms included as Appendix A and described in Sections 2,3,4 and 5
respectively,and the Operating Foreman's Daily Inspection and Weekly Mill Inspection forms
described in Sections 2 and 3,respectively,the following additional reports shall also be prepared:
8.1.Monthly Tailings Reports
Monthly tailings reports are prepared every month and summarize the previous month's activities
around the tailings area.If not prepared by the Radiation Safety Officer,the report shall be
submitted to the Radiation Safety Officer for review.The Mill Manager will review the report as
well before the report is filed in the Mill Central File.The report will contain a summary of
observations of concern noted on the daily and weekly tailings inspections.Corrective measures
taken during the month will be documented along with the observations where appropriate.All daily
and weekly tailings inspection forms will be attached to the report.A monthly inspection form will
also be attached.Quarterly inspection forms will accompany the report when applicable.The report
will be signed and dated by the preparer in addition to the Radiation Safety Officer and the Mill
Manager.
White Mesa Mill-Standard Operating Procedures
Book II:Environmental Protection Manual,Section 3.1
8.2.DMT Reports
~JlQ9.!.Q Revision:Denison-32
Page 22 of46
QUaJ1erly rcp0l1s of DMT monitoring activities,which will include the following information.will
be provided to the Executive Secretary on the schedule provided in Table 5 of the GWDP:
al On a quarterly basis,all required information required by Pan I.F.2 ofthe GWDP
relating to the inspections described in Section 3.1(b)(Slimes Drain Water Level
Monitoring),3.I(d)(Tailings Wastewater Pool and Beach Area Elevation
Monitoring),3.2 (Weekly Inspection ofSolution Levels in Roberts Pond)and 3.3
(Weekly Feedstock Storage Area lnspections)~
bl On a guuI1erly basis.a sumlllary of the daily water level (depth)inspections for
the quarter for the presence of Ollie!in all three vertical inspection (l0l1als for each
of the three chambers in the concrete ~elliing lank system for the New
Decontamination Pad.which will include a table indicating the water level
measurements in each portal during the quarter:
c)With respect to the annual inspection ofthe New Decontamination Pad described
in Section 6.5(a),the inspection findings.any repairs required,and repairs
completed !-hall be summarized in the 2nd Quarter report.due September 1 of
each calendar year;
eI)With respect to the annual inspection of the Existing Decontamination Pad
described in Section 6.5(b),the inspection findings.any repair!-.required,and
repairs completed shall bc summarized in the 2nd OUaJ1er report,due September I
of each calendar year:and
e)will ee f,lFeviEleElto lJle exeeutive SeereHlry OR the sehec:ll:lle f,lro¥ic:lec:l in Table 5
of tfle GWDP.An annual summaryand graph for each calendar year ofthe depth
to wastewater in the Cell 2 slimes drain must be included in Lhe fourth quarter
report.After the first year,and beginning in 2008,quarterly reports shall include
both the current year monthly values and a graphic comparison to the previous
year.
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
APPENDIX A
FORMS
Revision:Denison-82
Page 23 of 46
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
Revision:Denison-&2
Page 24 of46
APPENDIX A (CONT.)
DAILY INSPECTION DATA
Any Item not "OK"must be documented.A check mark =OK,X =Action Required
Inspector:_
Date;._
Accompanied by:_
Time:,_
I.TAILINGS SLURRY TRANSPORT SYSTEM I
Insoection Items Conditions of Potential Concern CellI Cell 2 Cell 3 Ce1l4A
Slurry Pipeline Leaks,Damage,Blockage,Sharp Bends
Pipeline Joints Leaks,Loose Connections
Pipeline Supports Damage,Loss of Support
Valves Leaks,Blocked,Closed
Point(s)of Discharge Improper Location or Orientation
II.OPERATIONAL SYSTEMS I
Insoection Items Conditions of Potential Concern CellI Cell 2 Cell 3 Ce1l4A
Water Level Greater Than Operating Level,Large Change
Since Previous Inspection
Beach Cracks,Severe Erosion,Subsidence
Liner and Cover Erosion ofcover,Exposure ofLiner
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
Revision:Denison-,\?2
Page 25 of 46
III.DIKES AND EMBANKMENTS I
Inspection Items Conditions of Potential Concern Dike Dike 1-Dike 2 Dike 3 Dike 4A-Dike 4A-
I-I lA S W
Slopes Sloughs or Sliding Cracks,Bulges,Subsidence,
Severe Erosion,Moist Areas,Areas of Seepage
Outbreak
Crest Cracks,Subsidence,Severe Erosion
IV.FLOW RATES I
Slurrv Line(s)Pond Return S-X Tails Sprav Svstem
GPM
V.PHYSICAL INSPECTION OF SLURRY LINES(S)
Walked to Discharge Point
Observed Entire Discharge Line
______yes
______yes
______No
_____~No
VI.DUST CONTROL
Cell 2 Cell 3 Cell 4A
Dusting
Wind Movement of Tailings
Precipitation:inches liquid
General Meteorological conditions:
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
Revision:Denison-&2
Page 26 of 46
VII.DAILY LEAK DETECTION CHECK I
CellI Cell 2 Cell 3 Ce1l4A
Leak Detection System Checked Checked Checked Checked
Checked
Wet Dry Wet Dry Wet Dry Wet Dry
Initial level Initial level Initial level Initial level
Final level Final level Final level Final level
Gal.pumped Gal.pumped Gal.pumped Gal.pumped
VIII OBSERVATIONS OF POTENTIAL CONCERN Action Required
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
[MAP OF TAILINGS AREA]
Revision:Denison-.g2
Page 27 of46
White Mesa Mill Standard Operating Procedures
Book II:Environmental Protection Manual,Section 3.1
APPENDIX A (CONT)
Revision:Denison-&.2
Page 28 of 46
__5564__
__5612.34_
Date:_
1.Pond and Beach
elevations (msl,ft)
DENISON MINES (USA)CORP.
WEEKLY TAILINGS INSPECTION
Inspectors:_
Cell 1:(a)Pond Solution Elevation
(b)FML Bottom Elevation 5597 _
(c)Depth of Water above FML «a)-(b))_
Cell4A:(a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth ofWater above FML «a)-(b))_
(d)Elevation of Beach Area
with Highest elevation (monthly)
Roberts
Pond:(a)Pond Solution Elevation
(b)FML Bottom Elevation
(c)Depth of Water above FML «a)-(b))_
2.Slimes Drain Liquid Levels Cell 2 Pump functioning properly _
Pump Timer set at 15min on 45 min off _
_______Depth to Liquid pre-pump
_______Depth to Liquid Post-pump
(all measurements are depth-in-pipe)
Pre-pump head is 38'-Depth to Liquid Pre-pump =
Post-pump head is 38'-Depth to Liquid Post-
pump=_
White Mesa Mill -Standard Operating Procedures
Book II:Environmental Protection Manual.Section 3.1
3.Leak Detection Systems
~1!09l.QRevision:Denison-8,2
Page 29 of46
Observation:
Cell I Cell 2 Cell 3 Cell4A
Is LDS wet or drv?wet d~wet dry wet dry wet dry
If wet,Record FIIO Ft to Flto Ft to
Hnuid lcvcl:Linuid Liouid Linuid Linuid *
I If sufficient fluid is Volulllc Volumc Volume Volume
present.record Flow Rate Flow Ratc Flow Rate Flow Rate
volume of fluid
pumped and flow
rate:
I Was fluid sample -yes__no -yes__no -yes__no -yes__no
collectcd?
Observation:
New Deeon Pad,New Pecan Pad.New Decon Pad
Ponal I Ponal2 Portal 3
Is LDS (Portal)drywetdrywet wet dry
wet or d"'?
Ifwct.Record Ft to FI to Ft 10
ii';uid level:Lie uicl Lie uid liQuid
Ifwet.Report to
RSO
4.Tailings Area Inspection (Note dispersal of blowing tailings):
5.Control Methods Implememed::_
6.Remarks::_
7.Contaminated Waste Dump:
White Mesa Mill -Standard Operating Procedures
Book II:Environmental Protection Manual,Section 3.1
~lIQ9lQ Revision:Denison-&,2
Page 30 or46
Decontamination Pad In~pections
Concrete Inhih'Concrete IntcfJritv
New Decon Pad Existinn Decon Pad
Cheded Checked
Are there any crack!';on Ihe Arc there any cracks on the
wash pad surface greater wa~h pad surface greater
than 1/8 inch of than 1/8 inch of
!';cparation?Yes No separation?Yes No
Contact the RSO if a Contact the RSO If a
problem has been problem has been
observed.oho;;clYed.
Remark~(including a deSCription ofany abnom13htlcs relating to the New Decon Pad or Exi~ting Ocean
Padl
•Docs Level exceed 12 inches above the lowest point on the bOllom flexible membrane liner (elevation
5556.14 amsl)?no __yes
IrCe1l4A leak detection system level exceeds 12 inches above the lowest point ol1lhe bottom flexible
membrane liner (elevation 5556.14 amsl),notify supervisor or Mill manager immediately.
White Mesa Mill Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
APPENDIX A (CONT.)
Revision:Denison-~'<;l
Page 31 of46
MONTHLY INSPECTION DATA
Inspector:.
Date:_
1.Slurry Pipeline:
Pipe Thickness:(To be measured only during periods when the Mill is operating)
2.Diversion Ditches and Diversion Berm:
Observation:
Diversion Ditch 1 Diversion Ditch 2 Diversion Ditch 3 Diversion Berm 2
Diversion Ditches:
Sloughing
Erosion
Undesirable
Vegetation
Obstruction ofFlow
Diversion Berm:
Stability Issues
Signs of Distress
__yes__no
__yes__no
__yes__no
----yes__n0
__yes__no
__yes__no
__yes__no
__yes__no
__yes__no
__yes__no
__yes__no
__yes__no
__yes__no
__yes__no
Comments:_
3.Summary of Activities Around Sedimentation Pond:_
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
4.Overspray Dust Minimization:
Revision:Denison-g2
Page 32 of 46
Overspray system functioning properly:___yes no
Overspray carried more than 50 feet from the cell:__yes no
If "yes",was system immediately shut off?__yes__no
Comments:_
5.Remarks:_
6.Settlement Monitors
Cell 2 WI:
Cell 2 W2:
Cell 2 W3:
Cell 2 W4:
Cell 2W7-C:_
Cell 2 W7N:_
Cell 2 W6C:_
Cell 4A-Toe:_
Cell 3-2C:_
Ce1l2W3-S:
CeIl2E1-N:_
Ce1l2E1-1S:_
CeIl2El-2S:_
Cell 2 East:
Cell 2 W7S:_
Cell 2 W6S:_
Cell 2 W4S:_
Cell 3-2S:_
CeIl3-1N:_
Ce1l3-1C:_
Cell 3-1S:_
Cell 3-2N:_
Cell 2W5-N:_
Cell 2 W6N:
Cell 2 W4N:
Cell 2 W5C:
7.Summary of Daily,Weekly and Quarterly Inspections:_
8.Monthly Slimes Drain Static Head Measurement for Cell 2 (Depth-in-Pipe Water Level
Reading):
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
APPENDIX A (CONT.)
Revision:Denison-&<t
Page 33 of 46
WHITE MESA MILL
TAILINGS MANAGEMENT SYSTEM
QUARTERLY INSPECTION DATA
Inspector:_
Date:_
1.Embankment Inspection:_
2.OperationslMaintenance Review:
3.Construction Activites:_
4.Summary:_
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
APPENDIX A (CONT.)
Revision:Denison-&2
Page 34 of 46
ORE STORAGE/SAMPLE PLANT WEEKLY INSPECTION REPORT
Week of through Date of Inspection:_
Inspector:.
Weather conditions for the week:
Blowing dust conditions for the week:
Corrective actions needed or taken for the week:
Are all bulk feedstock materials stored in the area indicated on the attached diagram:
yes:no:_
comments:_
Are all alternate feedstock materials located outside the area indicated on the attached diagram maintained
within water-tight containers:
yes:no:_
comments (e.g.,conditions of containers):_
Conditions of storage areas for materials:
Other comments:
White Mesa Mill-Standard Operating Procedures
Book II:Environmental Protection Manual,Section 3.1
~J/Q9.!.Q Revision:Denison-8,2
Page 35 of46
APPENDIX A CCONT.)
A VAL DECONTAMI ATION PAD lNSPECTIO
Date of Inspection:
Inspector:
New Decontamination Pad:
Are there lIIW cmcks on the wash pad !>urface grcatcr than 1/8 inch of SCplll<ll;on?Yes No
Is there any significant deteriomtion or damage ofthe pad !>urface?
Findings:
Repair War!..Required.
Existing Decontamination Pad:
Yes No
Were there any observed problems with the S1eeltank?
Findings:
Repair Work Required:
Yes No
White Mesa Mill -Standard Operating Procedures
Book II:Environmental Protection Manual,Section 3.1
APPENDIXB
Revision:Denison-82
Page 36 of46
TAILINGS INSPECTOR TRAINING
This document provides the training necessary for qualifying management-designated individuals for
conducting daily tailings inspections.Training information is presented by the Radiation Safety
Officer or designee from the Environmental Department.Daily tailings inspections are conducted in
accordance with the White Mesa Mill Tailings Management System and Discharge Minimization
Technology (DMT)Monitoring Plan.The Radiation Safety Officer or designee from the Radiation
Safety Department is responsible for performing monthly and quarterly tailings inspections.Tailings
inspection forms will be included in the monthly tailings inspection reports,which summarize the
conditions,activities,and areas of concern regarding the tailings areas.
Notifications:
The inspector is required to record whether all inspection items are normal (satisfactory,requiring no
action)or that conditions ofpotential concern exist (requiring action).A "check"mark indicates no
action required.If conditions ofpotential concern exist the inspector should mark an "X"in the area
the condition pertains to,note the condition,and specify the corrective action to be taken.If an
observable concern is made,it should be noted on the tailings report until the corrective action is
taken and the concern is remedied.The dates ofall corrective actions should be noted on the reports
as well.
Any major catastrophic events or conditions pertaining to the tailings area should be reported
immediatelyto the Mill Manager or the Radiation Safety Officer,one ofwhom will notify Corporate
Management.Ifdam failure occurs,notify your supervisor and the Mill Manager immediately.The
Mill Manager will then notify Corporate Management,MSHA (303-231-5465),and the State of
Utah,Division of Dam Safety (801-538-7200).
Inspections:
All areas of the tailings disposal system are routinely patrolled and visible observations are to be
noted on a daily tailings inspection form.Refer to Appendix A for an example of the daily tailings
inspection form.The inspection form consists of three pages and is summarized as follows:
1.Tailings Slurry Transport System:
The slurry pipeline is to be inspected for leaks,damage,and sharp bends.The pipelinejoints
are to be monitored for leaks,and loose connections.The pipeline supports are to be
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
Revision:Denison-Wi
Page 37 of46
inspected for damage and loss of support.Valves are also to be inspected particularly for
leaks,blocked valves,and closed valves.Points of discharge need to be inspected for
improper location and orientation.
2.Operational Systems:
Operating systems including water levels,beach liners,and covered areas are items to be
inspected and noted on the daily inspection forms.Sudden changes in water levels
previously observed or water levels exceeding the operating level of a pond are potential
areas ofconcern and should be noted.Beach areas that are observed as having cracks,severe
erosion or cavities are also items that require investigation and notation on daily forms.
Exposed liner or absence of cover from erosion are potential items ofconcern for ponds and
covered areas.These should also be noted on the daily inspection form.
Cells 1,3 and 4A solution levels are to be monitored closely for conditions nearing
maximum operating level and for large changes in the water level since the last inspection.
All pumping activities affecting the water level will be documented.In Cells 1 and 3,the
PVC liner needs to be monitored closely for exposed liner,especially after storm events.It is
important to cover exposed liner immediately as exposure to sunlight will cause degradation
of the PVC liner.Small areas ofexposed liner should be covered byhand.Large sections of
exposed liner will require the use of heavy equipment
These conditions are considered serious and require immediate action.After these conditions
have been noted to the Radiation Safety Officer,a work order will be written by the
Radiation Safety Officer and turned into the Maintenance Department.All such repairs
should be noted in the report and should contain the start and finish date of the repairs.
3.Dikes and Embankments:
Inspection items include the slopes and the crests of each dike.For slopes,areas ofconcern
are sloughs or sliding cracks,bulges,subsidence,severe erosion,moist areas,and areas of
seepage outbreak.For crests,areas of concern are cracks,subsidence,and severe erosion.
When any of these conditions are noted,an "X"mark should be placed in the section marked
for that dike.
In addition,the dikes,in particular dikes 3,4A-S and 4A-W,should be inspected closely for
mice holes and more importantly for prairie dog holes,as the prairie dogs are likely to
burrow in deep,possibly to the liner.If any of these conditions exist,the inspection report
should be marked accordingly.
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
4.Flow Rates:
~,.'1·(}7 I \J Revision:Denison-&2
Page 38 of46
Presence ofall flows in and out of the cells should be noted.Flow rates are to be estimated
in gallons per minute (GPM).Rates need to be determined for slurry lines,pond return,SX-
tails,and the spray system.During non-operational modes,the flow rate column should be
marked as "0".The same holds true when the spray system is not utilized.
5.Physical Inspection ofSlurry Line(s):
A physical inspection of all slurry lines has to be made every 4 hours during operation of the
mill.Ifpossible,the inspection should include observation of the entire discharge line and
discharge spill point into the cell.If "fill to elevation"flags are in place,the tailings and
build-up is to be monitored and controlled so as to not cover the flags.
6.Dust Control:
Dusting and wind movement of tailings should be noted for Cells 2,3,and 4A.Other
observations to be noted include a brief description of present weather conditions,and a
record of any precipitation received.Any dusting or wind movement oftailings should be
documented.In addition,an estimate should be made for wind speed at the time of the
observed dusting or wind movement of tailings.
The Radiation Safety Department measures precipitation on a daily basis.Daily
measurements should be made as near to 8:00 a.m.as possible every day.Weekend
measurements will be taken by the Shifter as close to 8:00 a.m.as possible. All snow or ice
should be melted before a reading is taken.
7.Observations of Potential Concern:
All observations ofconcern during the inspection should be noted in this section.Corrective
action should follow each area of concern noted.All work orders issued,contacts,or
notifications made should be noted in this section as well.It is important to document all
these items in order to assure that the tailings management system records are complete and
accurate.
8.Map ofTailings Cells:
The last section of the inspection involves drawing,as accurately as possible,the following
items where applicable.
1.Cover area
2.Beach/tailing sands area
White Mesa Mill -Standard Operating Procedures
Book II:Environmental Protection Manual,Section 3.1
Revision:Denison-&2
Page 39 of46
3.Solution as it exists
4.Pump lines
5.Activities around tailings cell (i.e.hauling trash to the dump,liner repairs,etc.)
6.Slurry discharge when operating
7.Over spray system when operating
9.Safety Rules:
All safety rules applicable to the mill are applicable when in the tailings area.These rules
meet the required MSHA regulations for the tailings area.Please pay particular notice to the
following rules:
1.The posted speed limit for the tailings area is 15 mph and should not be exceeded.
2.No food or drink is permitted in the area.
3.All personnel entering the tailings area must have access to a two-way radio.
4.Horseplay is not permitted at any time.
5.Only those specifically authorized may operate motor vehicles in the restricted area.
6.When road conditions are muddy or slick,a four-wheel drive vehicle is required in the
area.
7.Any work performed in which there is a danger of falling or slipping in the cell will
require the use of a safety belt or harness with attended life line and an approved life
jacket.A portable eyewash must be present on site as well.
8.Anytime the boat is used to perform any work;an approved life jacket and goggles must
be worn at all times.There must also be an approved safety watch with a two-way hand-
held radio on shore.A portable eyewash must be present on site as well.
10.Preservation of Wildlife:
Every effort should be made to prevent wildlife and domesticated animals from entering the
tailings area.All wildlife observed should be reported on the Wildlife Report Worksheet
during each shift.WaterfowIseen near the tailings cells should be discouraged from landing
by the use of noisemakers.
11.Certification:
Following the review of this document and on-site instruction on the tailings system
inspection program,designated individuals will be certified to perform daily tailings
inspections.The Radiation Safety Officer authorizes certification.Refer to the Certification
Form,Appendix C.This form should be signed and dated only after a thorough review ofthe
tailings information previously presented.The form will then be signed by the Radiation
Safety Officer and filed.
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
APPENDIXC
CERTIFICATION FORM
Date:_
Name:_
Revision:Denison-g2
Page 40 of46
I have read the document titled "Tailings Management System,White Mesa Mill Tailings
Inspector Training"and have received on-site instruction at the tailings system.This instruction
included documentation of daily tailings inspections,analysis of potential problems (dike
failures,unusual flows),notification procedures and safety.
Signature
I certify that the above-named person is qualified to perform the daily inspection of the tailings
system at the White Mesa Mill.
Radiation Safety Personnel!Tailings System
Supervisor
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
'7.'IV7I\I Revision:Denison-82
Page 41 of46
APPENDIXD
FEEDSTOCK STORAGE AREA
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
APPENDIXE
TABLES
Revision:Denison-&2
Page 42 of46
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
Table 1
Revision:Denison-&2
Page 43 of46
Calculated Action leakage Rates
for Various head Conditions
Cell 4A White mesa Mill
Blanding,Utah
Head above Liner System (feet)Calculated Action leakage Rate
(gallons /acre /day)
5 222.04
10 314.01
15 384.58
20 444.08
25 496.50
30 543.88
35 587.46
37 604.01
White Mesa Mill -Standard Operating Procedures
Book II:Environmental Protection Manual,Section 3.1
APPENDIXF
Example ofFreeboard Calculations
For Cell4A
Assumptions and Factors:
Revision:Denison-g2
Page 44 of46
o Total PMP volume to be stored in Cell 4A -159.4 acre feet
o Wave runup factor for Cell4A -0.77 feet
o Total capacity of Cell 4A -2,094,000 dry tons
o Elevation of FML of Cell 4A -5,598.5 FMSL
o Maximum pool surface area of Cell 4A -40 acres
o Total tailings solids deposited into Cell 4A at time beach area first exceeds 5,593
FMSL -1,000,000 dry tons*
o Date beach area first exceeds 5,593,FMSL -March 1,2009*
o Expected and actual production is as set forth in the following table:
Time Period Expected Expected Actual Tailings
Tailings Solids Tailings Solids
Disposition into Solids Disposition into
Cell 4A Dispositio Cell 4A
Determined at n into Cell determined at
the beginning of 4A at the end of the
the period (dry beginning period (dry
tons)*of the tons)*
period,
multiplied
by 150%
Safety
Factor
(dry tons)
March 1,2009 150,000 225,000 225,000
to November 1,
2009
November 1,300,000 450,000 275,000
2009 to
November 1,
2010
November 1,200,000 300,000 250,000
2010 to
November 1,
2011
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
Revision:Denison-&2
Page 45 of 46
*These expected and actual tailings and production numbers and dates are fictional and have
been assumed for illustrative purposes only.
Based on these assumptions and factors,the freeboard limits for Cell4A would be calculated
as follows:
1.Prior to March 1,2009
Prior to March 1,2009,the maximum elevation of the beach area in Cell 4 is less than or
equal to 5,593 FMSL,therefore the freeboard limit is set at 5,593.7 FMSL.
2.March 1,2009 to November 1,2009
The pool surface area would be reduced to the following amount
(1 -225,000/(2,094,000 -1,000,000))x 40 acres =31.77 acres
Based on this reduced pool area,the amount offreeboard would be 159.4 acre feet divided by 31.77
acres equals 5.02 feet.When the wave run up factor for Cell 4A of0.77 feet is added to this,the total
freeboard required is 5.79 feet.This means that the freeboard limit for Cell4A would be reduced
from 5593.7 FMSL to 5592.7 FMSL (5598.5 FMSL minus 5.79 feet,rounded to the nearest one-
tenth of a foot).This calculation would be performed at March 1,2009,and this freeboard limit
would persist until November 1,2009.
3.November 1,2009 to November 1,2010
The pool surface area would be reduced to the following amount:
First,recalculate the pool surface area that should have applied during the previous period,
had modeled tonnages (i.e.,expected tonnages grossed up by the 150%safety factor)equaled
actual tonnages for the period.Since the actual tonnage of225,000 dry tons was the same as
the modeled tonnage of 225,000 dry tons,the recalculated pool surface area is the same as
the modeled pool surface area for the previous period,which is 31.77 acres.
Then,calculate the modeled pool surface area to be used for the period:
(1-450,000/(2,094,000 -1,000,000 -225,000))x 31.77 acres =15.32 acres
Based on this reduced pool area,the amount offreeboard would be 159.4 acre feet divided by
15.32 acres equals 10.40 feet.When the wave run up factor for Cell4A of0.77 feet is added
to this,the total freeboard required is 11.17 feet.This means that the freeboard limit for Cell
4A would be reduced from 5592.7 FMSL to 5587.3 FMSL(5598.5 FMSLminus 11.17 feet,
rounded to the nearest one-tenth of a foot).This calculation would be performed at
November 1,2009,and this freeboard limit would persist until November 1,2010.
White Mesa Mill -Standard Operating Procedures
Book 11:Environmental Protection Manual,Section 3.1
4.November 1,2010 to November 1,2011
Revision:Denison-&2
Page 46 of 46
The pool surface area would be reduced to the following amount:
First,recalculate the pool surface area that should have applied during the previous period,
had modeled tonnages (i.e.,expected tonnages grossed up by the 150%safety factor)equaled
actual tonnages for the period.Since modeled tonnages exceeded actual tonnages,the pool
area was reduced too much during the previous period,and must be adjusted.The
recalculated pool area for the previous period is:
(1-275,000/(2,094,000 -1,000,000 -225,000)x 31.77 acres =21.72 acres.
This recalculated pool surface area will be used as the starting point for the freeboard
calculation to be performed at November 1,2010.
Then,calculate the modeled pool surface area to be used for the period:
(1 -300,000/(2,094,000 -1,000,000 -225,000 -275,000))x 21.72 acres =
10.75 acres
Based on this reduced pool area,the amount offreeboard would be 159.4 acre feet divided by
10.75 acres equals 14.83 feet.When the wave run up factor for Cell4A of 0.77 feet is added
to this,the total freeboard required is 15.60 feet.This means that the freeboard limit for Cell
4A would be reduced from 5587.3 FMSLto 5582.9 FMSL(5598.5 FMSL minus 15.60 feet,
rounded to the nearest one-tenth of a foot).This calculation would be performed at
November 1,2010,and this freeboard limit would persist until November 1,2011.
Attachment B
While Mesa Mill -Slandard
Operating Procedures
Book #19-Groundwater
Discharge Permil Plans and
Procedures
Dale:8J/G8lQ Revision:OUSA-
1>
Page 1of 14
WHITE MESA URANIUM MILL
CONTINGENCY PLAN
As Refluired UndeFConremplated by Part ~I.G.4(d)
of
State of Utah Groundwater Discharge Permit No.UGW370004
Prepared by:
Denison Mines (USA)Corp.
1050 17~Street,Suite 950
Denver CO 80265
AuguSI 8March 12,200810
While Mesa Mill -Standard
Operating Procedures
Book #19 -Groundwater
Discharge Permit Plans and
Procedures
TABLE OF CONTENTS
I.INTRODUCfION
2.PURPOSE
3.GROUNDWATER CONTAMINATION
3.1.Notification
3.2.COnlinuation of Accelerated Monitoring
3.3.Submission of Plan and Timetable
3.4.Groundwater Remediation Plan
Date:8:Yij8l.Q Revision:DUSA->.
Page 2 of 14
3
3
4
4
4
5
4.MILL DISCHARGE VIOLATIONS -INCLUDING
UNAUTHORIZED DISCHARGE OR RELEASE OF PROHIBITED
CONTAMINANTS TO THE TAILING CELLS
4.1.Notifications
4.2.Field Activities
4.3.Request for Approvals and/or Waivers
5.DMT VIOLATIONS
5.1.Tailings Cell Wastewater Pool Elevation Above the Maximum
Elevations
5.2.Excess Head in Tailings Cells 2 and 3 Slimes Drain Systems
5.3.Excess Cell4A Leak Detection Fluid Head or Daily Leak Rate
5.4.Excess New Decontamination Pad Leak Detection Fluid Head
~5.5.Excess Elevation For Tailings Solids
~5.6.Roberts Pond Wastewater Elevation
~5.7.Feedstock Storage Area
~5.8.Mill Site Chemical Reagent Storage
~5.9.Failure to Construct as per Approval
~5.1O.Failure to Comply with Stormwater Management and Spill
Control Requirements
5
6
6
6
7
7
8
9
2
9l.Q
119
119
11+
lJ.~
lJ.~
White Mesa Mill -Standard
Operating Procedures
Book #19-Grouoowater
Discharge Permit Plans and
Procedures
Date:&:YG8lQ Revision:DUSA-
+2.
Page 3 of 14
WIDTE MESA URANIUM MILL
CONTINGENCY PLAN
State of Utah Groundwater Discharge Permit
No.UGW370004
1.INTRODUCTION
The State of Utah has granted Ground Water Discharge Permit No.UGW370004 (the
"GWDP")for Denison Mines (USA)Corp.'s ("Denison's")White Mesa Uranium Mill
(the "Mill").The GWDP specifies the construction,operation,and monitoring
requirements for all facilities at the Mill that have a potential to discharge pollutants
directly or indirectly into groundwater.
2.PURPOSE
This Contingency Plan (the "Plan")provides a detailed list of actions Denison will take to
regain compliance with GWDP limits and Discharge Minimization Technology ("DMT')
requirements defined in Parts LC.-&RtI J.D.and 1.1-1.4 of the GWDP.The timely execution
of contingency and corrective actions outlined in this Plan will provide Denison with the
basis to exercise the Affirmative Action Defense provision in Part I.G.3.c)of the GWDP
and thereby avoid noncompliance status and potential enforcement actionI,
The contingency actions required to regain compliance with GWDP limits and DMT
requirements defined in Parts I.C.-&f*I J.D,and 1.1-1.4 of the GWDP are described below.
3.GROUNDWATER CONTAMINATION
Since there arc many different possible scenarios that could potentially give rise to
groundwater contamination,and since the development and implementation of a
remediation program will normally be specific to each particular scenario,this Plan does
not outline a definitive remediation program.Rather,this Plan describes the steps that
will be followed by Denison in the event Denison is found to be out of compliance with
respect to any constituent in any monitoring well,pursuant to Part I.G.2 of the GWDP.
When the concentration of any parameter in a compliance monitoring well is out of
compliance,Denison will,subject to specific requirements of the Executive Secretary as
1 Part l.G.3.c)of lhe GWDP provides that,in the event a compliance action is initiated against Denison for
violation ofpermit conditions relating to best available technology or DMT.Denison may affirmatively
defend against that action by demonstrating that it has made appropriate notifications.that the failure was
not intentional or caused by Denison's negligence,thaI Denison has laken adequate measures to meet
permit conditions in a limely manner or has submiued an adequate plan and schedule for meeting permit
conditions,and that the provisions ofUCA 19-5-107 have nOI been violated.
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set forth in any notice,order,remediation plan or the equivalent,implement the following
process:
3.1.Notification
Denison will notify the Executive Secretary of the out of compliance status within 24
hours after detection of that status followed by a written notice within 5 days after
detection,as required under Part LOA.a)of the OWDP.
3.2.Continuation of Accelerated Monitoring
Denison will continue accelerated sampling for the parameter in that compliance
monitoring well pursuant to Part 1.0.1 of the OWDP,unless the Executive Secretary
determines that other periodic sampling is appropriate,until the facility is brought into
compliance,as required under Part LO.4.b)of the OWDP.
If the accelerated monitoring demonstrates that the Mill is no longer out of compliance
with respect to a parameter in a well,then,with the written approval of the Executive
Secretary,Denison will cease accelerated monitoring for the parameter,and no further
steps will be followed by Denison with respect to such parameter.
3.3.Submission of Plan and Timetable
If the accelerated monitoring confirms that the Mill is out of compliance with respect to a
parameter in a well,then,within 30 days of such confirmation,Denison will prepare and
submit to the Executive Secretary a plan and a time schedule for assessment of the
sources,extent and potential dispersion of the contamination,and an evaluation of
potential remedial action to restore and maintain ground water quality to ensure that
permit limits will not be exceeded at the compliance monitoring point and that DMT will
be reestablished,as required under part LOA.c)of the OWDP.This plan will normally
include:
a)The requirement for Denison to prepare a detailed and comprehensive
operational history of the facility and surrounding areas which explores all
activities that may have contributed to the contamination;
b)A requirement for Denison to complete an evaluation,which may include
geochemical and hydrogeological analyses,to determine whether or not the
contamination was caused by Mill activities or was caused by natural forces or
offsite activities;
c)If it is concluded that the contamination is the result of current or past activities
at the Mill,Denison will prepare a Characterization Report,which characterizes
the physical,chemical,and radiological extent of the ground water
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contamination.This will normally include a description of any additional wells
to be used or installed to characterize the plume and the hydrogeologic
characteristics of the affected zone,the analytical parameters to be obtained,the
samples of ground water to be taken,and any other means to measure and
characterize the affected ground water and contamination zone;and
d)If it is concluded that the contamination is the result of current or past activities
at the Mill,Denison will evaluate potential remedial actions,including actions to
restore and maintain groundwater quality to ensure that permit limits will not be
exceeded at the compliance monitoring point and that DMT will be reestablished,
as well as actions that merely allow natural attenuation to operate and actions that
involve applying for Alternate Concentration Limits ("ACLs").If groundwater
remediation is required,Denison will prepare and submit to the Executive
Secretary a Ground Water Remediation Plan,as described in Section 3.4 below.
3.4.Groundwater Remediation Plan
If the Executive Secretary determines that ground water remediation is needed,Denison
will submit a Ground Water Remediation Plan to the Executive Secretary within the time
frame requested by the Executive Secretary.The Ground Water Remediation Plan will
normally include:
a)A description and schedule of how Denison will implement a corrective action
program that prevents contaminants from exceeding the ground water protection
levels or ACLs at the compliance monitoring point(s)or other locations approved
by the Executive Secretary,by removing the contaminants,treating them in
place,or by other means as approved by the Executive Secretary;
b)A description of the remediation monitoring program to demonstrate the
effectiveness of the plan;and
c)Descriptions of how corrective action will apply to each source ofthe pollution.
Denison will implement the Ground Water Remediation Plan in accordance with a
schedule to be submitted by Denison and approved by the Executive Secretary.
4.MILL DISCHARGE VIOLATIONS -INCLUDING UNAUTHORIZED
DISCHARGE OR RELEASE OF PROHIBITED CONTAMINANTS TO THE
TAILING CELLS
Part I.C.2.of the GWDP provides that only lle.(2)by-product material authorized by the
Mill's State of Utah Radioactive Materials License No.UT-2300478 (the "Radioactive
Materials License")shall be discharged to or disposed of in the Mill's tailings cells.
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Part r.C.3 of the GWDP provides that discharge of other compounds into the Mill's
tailings cells,such as paints,used oil,antifreeze,pesticides,or any other contaminant not
defined as 11e.(2)material is prohibited.
In the event of any unauthorized disposal of contaminants or wastes (the "Unauthorized
Materials")to the Mill's tailings cells,Denison will,subject to any specific requirements
of the Executive Secretary as set forth in any notice,order,remediation plan or the
equivalent,implement the following process:
4.1.Notifications
a)Upon discovery,the Mill Manager or RSO will be notified immediately;and
b)Denison will provide verbal notification to the Executive Secretary within 24
hours ofdiscovery followed by a written notification within five days of
discovery.
4.2.Field Activities
a)Upon discovery,Mill personnel will immediately cease placement of
Unauthorized Materials into the Mill's tailings cells;
b)To the extent reasonably practicable and in a manner that can be accomplished
safely,Mill personnel will attempt to segregate the Unauthorized Materials from
other tailings materials and mark or record the location of the Unauthorized
Materials in the tailings cells.If it is not reasonably practicable to safely
segregate the Unauthorized Material from other tailings materials,Mill personnel
will nevertheless mark or record the location of the Unauthorized Materials in the
tailings cells;
c)To the extent reasonably practicable and in a manner that can be accomplished
safely,Mill personnel will attempt to remove the Unauthorized Material from the
tailings cells;and
d)Denison will dispose of the Unauthorized Material under applicable State and
Federal regulations.
4.3.Request for Approvals and/or Waivers
If it is not reasonably practicable to safely remove the Unauthorized Materials from the
tailings cells,then Denison will:
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a)Submit a written report to the Executive Secretary analyzing the health,safety
and environmental impacts,if any,associated with the permanent disposal of the
Unauthorized Material in the Mill's tailings cells;
b)Apply to the Executive Secretary for any amendments that may be required to the
GWDP and the Radioactive Materials License to properly accommodate the
permanent disposal of the Unauthorized Material in the Mill's tailings cells in a
manner that is protective of health,safety and the environment;and
c)Make all applications required under the United States Nuclear Regulatory
Commission's ("NRC's")Non-lle.(2)Disposal Policy,including obtaining
approval of the Department of Energy as the long term custodian of the Mill's
tailings,in order to obtain approval to permanently dispose of the Unauthorized
Material in the Mill's tailings cells.
5.DMTVIOLATIONS
5.1.Tailings Cell Wastewater Pool Elevation Above the Maximum Elevations
Part I.D.2 and Part I.D.6.d)of the GWDP provide that authorized operation and
maximum disposal capacity in each of the existing tailings cells shall not exceed the
levels authorized by the Radioactive Materials License and that under no circumstances
shall the freeboard be less than three feet,as measured from the top of the flexible
membrane liner ("FML").
In the event that tailings cell wastewater pool elevation in any tailings cell exceeds the
maximum elevations mandated by Part I.D.2 and Part I.D.6.d)of the GWDP,Denison
will,subject to any specific requirements ofthe Executive Secretary as set forth in any
notice,order,remediation plan or the equivalent,implement the following process:
a)Upon discovery,the Mill Manager or RSO will be notified immediately;
b)Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;
c)Upon discovery,Mill personnel will cease to discharge any further tailings to the
subject tailings cell,until such time as adequate freeboard capacity exists in the
subject tailings cell for the disposal of the tailings;
d)To the extent reasonably practicable,without causing a violation of the freeboard
limit in any other tailings cell,Mill personnel will promptly pump fluids from the
subject tailings cell to another tailings cell until such time as the freeboard limit
for the subject tailings cell is in compliance.If there is no room available in
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anolher tailings cell,wilhout violating the freeboard limit of such other cell,l.hen,
as soon as reasonably practicable,Mill personnel will cease to discharge any
further tailings to any tailings cell until such time as adequate freeboard capacity
exists in all tailings cells;
e)If it is not reasonably practicable to pump sufficient solutions from the subject
tailings cell to another tailings cell,then the solution levels in the subject tailings
cell will be reduced through natural evaporation;and
f)Denison will perform a root cause analysis of the exceedance and will implement
new procedures or change existing procedures to minimize the chance of a
recurrence.
5.2.Excess Head in Tailings Cells 2.3 and 4A Slimes Drain Systems
Part I.D.3.b)l)of the GWDP provides that Denison shall at all times maintain the average
wastewater head in the slimes drain access pipe in Cell 2 to be as low as reasonably
achievable,in accordance with athe Mill's currently approved DMT Monitoring Plan
al'll'lfeved I:ly ~ke e*eeutive Se€fe~BfYpUf!tUBlll Ie Part I.H.I]sf ~he GWDP,and that for
Cell 3,this requirement shall apply only after initiation of de·watering operations.
Similarly,Part I.D.6.c)of the GWDP provides that after Denison initiates pumping
conditions in the slimes drain layer in Cell 4A,Denison will provide,;"l,1 continuous
declining fluid heads in the slimes drain layer,in a manner equivalent to the requirements
found in Part I.D.3.b);and 2)a maximum head of 1.0 feet in the tailing$(as measured
from the lowest point of the upper FMU in 6.4 years or less.
In the event that the average wastewater head in the slimes drain access pipe for Cell 2 or,
aftcr initiation of dc-watering activities,Cell 3 or initiation of pumping conditions in the
slimes drain layer in Cell 4A exceeds the levels specified in the DMT Monitoring Plan,
Denison will,subject to any specific requirements of the Executive Secretary as set forth
in any notice,order,remediation plan or the equivalent,implement the following process:
a)Upon discovery,the Mill Manager or RSO will be notified immediately;
b)Mill personnel will promptly pump the excess fluid into an active tailings cell,or
other appropriate containment or evaporation facility approved by the Executive
Secretary;
c)If the exceedance is the result ofequipment failure,Mill personnel will attempt
to repair or replace the equipment;
d)If the cause of the exceedance is not rectified within 24 hours,Denison will
provide verbal notification to the Executive Secretary within the ensuing 24
hours followed by a written notification within five days;and
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e)If not due to an identified equipment failure,Denison will perform a root cause
analysis of the exceedance and will implement new procedures or change
existing procedures to minimize the chance of a recurrence.
5.3.Excess Ce1l4A Leak Detection System Fluid Head or Daily Leak Rate
Part I.D.6.a)provides that the fluid head in the Leak Detection System ("LOS")for Cell
4A shall not exceed I fOOl above the lowest point in the lower membrane liner,and Part
I.D.6.b)of the GWDP provides that the maximum allowable daily leak rate measured in
the LDS for Cell 4A shall not exceed 24,160 gallons/day.
In the event that the fluid head in the LDS for Cell 4A exceeds I foot above the lowest
point in the lower membrane layer or the daily leak rate measured in the Cell 4A LOS
exceeds 24,160 gallons/day,Denison will,subject to any specific requirements of the
Executive Secretary as set forth in any notice,order,remediation plan or the equivalent,
implement the following process:
a)Upon discovery,the Mill Manager or RSO will be notified immediately;
b)Mill personnel will promptly pump the excess fluid into an active tailings cell,or
other appropriate containment or evaporation facility approved by the Executive
Secretary,until such time as the cause of exceedance is rectified or until such
time as otherwise directed by the Executive Secretary;
c)If the exceedance is the result ofequipment failure,Mill personnel will attempt
to repair or replace the equipment;
d)[f the cause of the exceedance is not rectified within 24 hours,Denison will
provide verbal notification to the Executive Secretary within the ensuing 24
hours followed by a written nOlification within five days;and
e)[f not due to an identified equipment failure,Denison will perform a root cause
analysis of the exceedance and will implement new procedures or change
existing procedures to remediale the exceedance and to minimize the chance of a
recurrence.
5.4.Excess New Decontamination Pad Leak Detection System Fluid Head
In order to ensure that the primary containment of the New Decontamination Pad water
collection system has not been compromised.and to provide an inspection capability to
detect leakage from the primary containment in each of the three settling tanks.a vertical
inspection portal has been installed between the primary and secondary containment of
each settling tank.
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Section 3.1(e}ofthc Mill's DMT Monitoring Plan provide!>thatlhe nuid head in the LDS
for the New Decontamination Pad shall not exceed 0.10 feet above the concrete noar in
any of the three standpipes.
In the event that the nuid head in the standpipe for a selliing tank exceeds 0.10 feet above
the concrete noar in the standpipe,Denison will.~ubiectto any specilic requirements of
the Executive Secrelary as set fonh in any notice.order.remediation plan or the
equivalent.implemenlthe following process:
a)Upon discovery.the Mill Manager or RSO will be notiried immediately;
b)Denison will provide verbal notilicalion to the Executive Secretary within the
ensuing 24 hours followed by H wriLlen notification within five days;
c}Mill personnel will promptly pump the nuid from the seltling tank's LDS as well
as the nuids in thc sellling tank into another seLlling tank or into an active tailings
cell.ar other appropriate containment or evaporation facility approved by the
Executive Secretary,until such time as the cause of the exceedance is rectified or
until such time as otherwise directed by the Executive Secretary;and
d}Dcnison will perform a root causc analysi~ofthe exceedance and,if appropriate.
will implement new procedures or change existing procedures to remediate the
exceedance and to minimize the chance of a recurrence.
~5.5.Excess Elevation For Tailings Solids
Pall I.D.3.c)of the GWDP provides that upon closure of any tailings cell,Denison shall
ensure that the maximum elevation of the tailings waste solids does not exceed the top of
the FML
In the event that,upon closure of any tailings cell,the maximum elevation of the tailings
waste solids exceeds the top of the FML.Denison will,subject to any specific
requirements of the Executive Secretary as set fonh in any notice,order,remediation plan
or the equivalent,implement the following process:
a)Upon discovery,the Mill Manager or RSO will be notified immediately;
b)Denison will provide verbal notification to the Executive Secretary within 24
hours ofdiscovery followed by a written notification within five days of
discovery;
c)To the extent reasonably practicable,WitJlOut causing a violalion of the freeboard
limit in any other tailings cell,Mill personnel will promptly remove tailings
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solids from the subject tailings cell to another tailings cell,or other location
approved by the Executive Secretary,until such time as the maximum elevation
of the tailings waste solids in the subject tailings cell does not excecd the top of
the FML;and
d)Denison will perform a root cause analysis of the exceedance and will implement
new procedures or change existing procedures to minimize the chance of a
recurrence.
~5.6.Roberts Pond Wastewater Elevation
Part I.D.3.e)of the GWDP provides that the Permittee shall operate Robells Pond so as to
provide a minimum 2·foot freeboard at all times and that under no circumstances shall
the water level in Roberts Pond exceed an elevation of 5,624 feet above mean sea level.
In the event thaI the wastewater elevation exceeds this maximum level,Dcnison shall
remove the excess wastcwater and place it into containment in Tailings Cell I within 72
hours of discovery,as specified in Part I.D.3.e)of the GWDP.
In the event that,Denison fails to so remove any such excess wastewater,Denison will,
subject to any specific requirements of the Executive Secretary as set forth in any notice,
order,remediation plan or the equivalent,implement the following process:
a)Upon discovery,the Mill Manager or RSO will be notified immediately;and
b)Denison will provide verbal notification to the ExecUlive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions within five days ofdiscovery.
~5.7.Feedstock Storage Area
Part I.D.3.f)and Part 1.0.11 of the GWDP provide that open-air or bulk storage of all
feedstock materials at the Mill facility awaiting Mill processing shall be limited to the
eastern portion ofthe Mil1 site area described in Table 4 of the GWDP,and that storage
of feedstock materials at the facility outside that area shall be performed in accordance
with the provisions of 811 eppRweEi Feedsteck MallegeAleAl PieR pHFStiBtli Ie Part
I.HD.;!ll of the GWDP.
In the event that,storage of any feedstock at the Mill is not in compliance with the
requirements specified in Part I.D.3.f)and Part 1.0.11 of the GWDP,Denison will,
subject to any specific requirements of the Executive Secretary as set fOllh in any notice,
order,remediation plan or the equivalent,implement the following process:
a)Upon discovery,the Mill Manager or RSO will be notified immediately;
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b)Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification within five days of
discovery;
c)Mill persQlmel will:
(i)move any open-air or bulk stored feedstock materials to the portion of the
Mill site area described in Table 4 of the GWDP;
Oi)ensure that any feedstock materials that are stored outside of the area
described in Table 4 of the GWDP are stored and maintained in
accordance with the provisions of P.1I1 1.0.11 of the GWDP 8llprO'led
F'eedsl8ek Management Plan;and
(iii)to the extent that any such containers are observed to be leaking,such
leaking containers will be placed into watertight over-pack containers or
otherwise dealt with in accordance wiLh the provisions of Part l.0.11 of
the GWDPwilR lRe appFe..'ed F'eedst8el..Management PIllA,and any
impacted soils will be removed and will be deposited into the Mill's
active tailings cell;and
d)Denison will perfonn a root cause analysis of the non-compliant activity and will
implement new procedures or change existing procedures to minimize Lhe chance
of a recurrence.
~5.8.Mill Site Chemical Reagent Storage
Part I.D.3.g)of the GWOP provides that for all chemical reagents stored at existing
storage facilities,Denison shall provide secondary containment to capture and contain all
volumes of reagent(s)that might be released at any individual storage area,and that for
any new construction of reagent storage facilities,the secondary containment and control
shall prevent any contact of the spilled reagent with the ground surface.
In the event that Denison docs not provide the required secondary containment required
under Part I.D.3.g)of the GWDP,Denison will,subject to any specific requirements of
Lhe Executive Secretary as set forth in any notice,order,remediation plan or the
equivalent,implement the following process:
a)Upon discovery,the Mill Manager or RSO will be notified immediately;
b)Denison will provide verbal notification to the Executive Secretary within 24
hours ofdiscovery followed by a wriuen notification within five days of
discovery;and
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c)Denison will promptly remediate any spilled re-agent resulting from the failure to
provide the required secondary containment under Part I.D.3.g)of the GWDP,by
removal of the contaminated soil and disposal in the active tailings cell.
~5.9.Failure to Construct as per Approval
PaJ1 I.DA of the GWDP provides that any construction,modification,or operation of new
waste or wastewater disposal,treatment,or storage facilities shall require submittal of
engineering design plans and specifications,and prior Executive Secretary review and
approval,and that a Construction Permit may be issued.
In the event that,any new waste or wastewater disposal,treatment,or storage facilities
are constructed at the Mill facility without obtaining prior Executive Secretary review
and approval,or any such facilities are not constructed in accordance with the provisions
of any applicable Construction Permit,Denison will,subject to any specific requirements
of the Executive Secretary as set forth in any notice,order,remediation plan or the
equivalent,implement the following process:
a)Upon discovery,the Mill Manager or RSO will be notified immediately;and
b)Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a written notification and proposed corrective
actions witJlin five days of discovery.
~5.IO.Failure to Comply with Stormwater Managemcnt and Spill Control
Requirements
Part J.D.to of the GWDP provides that Denison will manage all contact and non-contact
stonnwater and control contaminant spills at the Mill facility in accordance with Mthe
currently approved Stormwater Best Management Practices Plan.fHIFSHl:Inl te Pelt 1.14.16
efll:1eGWDP.
In the event that any contact or non-contact stormwater or contaminant spills are not
managed in accordance with the Mill's approved Stormwater Best Management Practices
Plan,Denison will,subject to any specific requirements of the Executivc Secretary as set
forth in any notice,order,remediation plan or the equivalent,implement the following
process:
a)Upon discovery,the Mill Manager or RSO will be notified immediately;
b)Denison will provide verbal notification to the Executive Secretary within 24
hours of discovery followed by a wriLlen notification and proposed corrective
actions within five days of discovery;and
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c)To the extent still practicable at the time of discovery,Denison will manage any
such contaminant spill in accordance with the Mill's approved Stormwater Best
Management Practices Plan.To the extent it is no longer practicable to so
manage any such spill,Denison will agree with the Executive Secretary on
appropriate clean up and other measures.
Attachment C
November 13,2009
February 8,20 I0 Rev 1
Steve Snyder
Denison Mines (USA)Corp
P.O.Box 809
Blanding,UT 84511
[e-mail]
Subject:Concrete Mix Assessment
Permeability
Dear Mr.Snyder:
I have reviewed the concrete mix design that you sent to Mike Vuich on November 9,2009
(attached)and ofTer the following assessment:
I.The mix is a common design for fe'=4000 psi air entrained concrete with a water
reducing additive.This design has the general properties of medium strength with low
W/C ratio and good workability.Pemleability is low for this design as compared to
similar designs without the air entraining and water reducing admixes.
2.An actual value for penneability is difficult 10 dctennine from the mix design information
alone.It was likely in the range of 1.7xlfJ10 cm/s at 7 day Cllre,1.3.\"/UIO CllrlS at 28 day
cure,O.75.dUlflcllrls at one year and 0.45x1UIIJ CllrlS at ten years.I
I.COllcrete COIIstfllcliOl'Ellgil/eerit,g Hum/book.Edward G.Naw)',eRe Press,
LLC.,1997
(See also attached graph "Typical Concrete I>emlcability,Portland Cement,4000 pSI,-I"
Aggregate,W/C 0.50")
Without testing and rigorous analysis it is not possible to detennine the actual penneability of the
concrete in question.Assuming that the actual mix met the requirements of the mix design,the
concrete was placed and finished properly and it remains in good condition (no significant
damage,cracking,spalling,etc.)then penneability should be relatively low as compared to other
mix designs.
PRECISION SYSTEMS ENCINEERINC,,/illS Soulh!\GO Wr~ll Sandy.Ul.h H~071l
T~I~ft"~_lilt'""J1.'I.'I.'I.'I.I ~••IliA"'Ul..'I...n
I trust that this assessment is sufficient for your needs.If you need additional assistance with this
matter please contact me.
With best regards,
David P.Brown,P.E.,S.E.
Vice President,Operations
Cc:Mike Vuich
AHachments
Revision I:Corrected unit conversion errors
PRECISION SYSTEMS ENGINEERING I 'lOS SMilh 500 WnllSouod,..UtahI·unoT.I-.I.-,_••H.""".I~~I_n.J,-un
i'lUV iU Uti UL.V 1(;1
.i.'i
nVLUlJr\I v\JI'l0i r\UV IIVI'!p.l
~ee0G00000ee60aeoe00p.a~
HDlLUDAY CliJNSTRUC1fBDN,INt.
BOl(502
Blanding,Ulan 84511
[phone] -Office
[phone] -Residence
MIX ID SOND 600lA
CONCRE'rE MIX:m:S!GIlI
J 4000 PSI 01/2.4/96
exterior flatwork
564
123'1
~7J.8
33.2
G.O
WEIGHTS PER coale YAAD
nolnam Type r -III LB
~s~C33 Sand,LB
AST'M C33 *57 1"-Rock,LB
WATER,GAL-US (GA!J-US)
TOT,M,AIR,%
(SATURATED,·\Smu.~AeE-DRY>
'YIELD,eu FT
2.87
7.6'3
:lO.6'3
('33.2)4.44-
+/-1..0 LG3
Hill.Broa aICO 610 WRA,OZ
}fill nroa HlCO 30)Air,OZ
WATER/CEMENT RATIO,LBS!LB
SLUMP,IN
CONCRETE UNIT WEIGHT,PCI?
'rO'l'AL
16.92 V'6.0 v~
0.49 ~.
4.00 v,/
:L3!L Ii
.,
27.20
Note!Air dosage may be adju~ted to get 5-8 air in ooncrete
WRA do~age may be adjusted for up for hot or down tor cold weathe
Richard Warren
TYPICAL CONCRETE PERMEABILITY
PORTLAND CEMENT,4000 PSI,-1"AGGREGATE,WIC 0.50,WRA,6%AIR
PERMEABILITY v.CURE TIME
DATE PRINTED 2/10/2010
3.00E-l0
2.50E-l0
III 2.00E-l0-Ev
~::;1.50E-l0iii«w
:2
0:::
WQ.1.00E-l0
5.00E-ll
O.OOE+00 +----+-~,..-------_..,------
1 10 100
CURE TIME,days
1,000 10,000
Attachment D
NOTES:
1.\JASHDO\JN CHANNEL GRATING TO BE W'x2J!c,"BE.
2,PIPING FOR \JASHDO\JN IS TO BE FIELD RUN,
1 2 3 4 5 6
I
51'~3'-
A ~- -- -I llil I
EQUIPMENT 7/-3'
SPRAY /PAD
NOZZLES -
7 8 9 10
A
B
HEAT EXCHANGER
PLATFORM
SEE SHEET 7
[
B
SETTLING
TANK
SEE SHEET 3
c c
-----'WATER LINES
~SPRAY SHIELDING
SEE SHEET 7
D 95'D
E
I
'WASHDO'WN
CHANNELS
'WITH GRATING
~DISCHARGE
CHUTE
7-E
f
HANDRAIL
SEE SHEET 5
EL 5583,5 P.
:;:::':'.~':.",>',:,1:;:"":.:-'::;'''.::..•~;";~:'~~'>.~;..~':~"'.::;..;..';,j):.~;:';''':'.?~:~:;/:;:'~L~;';'::
E
SECTION 7-E
SCALE 3/16'=1'
F F
o
SCALE:
10
of 7
ENISOJ)~
MINES
9
SHEET 1
Title:
SIGNATURE DATE
DSGN:D\,tG:
SRS 11/12/09
DRV/N:SRS 11/12/09
APPR:RB 11/12/09
876
AS BUll T DRAwING
SUBMITTED FOR REVIEw
AND APPROVAL
54
Gtt-""-~-ELEV ATE D
PLATFORMS
SEE SHEET 4
321
G
1 I 2 I 3 I 4 I 5 I 6 I 7 I 8 I 9 I 10
A A
1--------31'-4'-----~~-#4 REBAR
1---11'-6'-~
1---14'-6'-~
r---8'-
B
-
NOTES:
1.SUBGRADE IS TO BE PREPARED 'v/ITH A 21.GRADE SLOPING FROM ALL AREAS TO
THE DISCHARGE OF THE DECON PAD,
2,SUBGRADE SHALL BE COMPOSED OF COMPACTED SOIL AND ROCK,
3,CONCRETE EXPANSION JOINTS SHALL BE DETERMINED AT INSTALLATION,
4,JOINTS SHOULD LEAVE A MINIMUM OF 24"OF PROTRUDING REBAR FOR THE NEXT
POUR,
5,REINFORCEMENT BAR TO BE USED SHALL BE #4 REBAR AND SHOULD BE LOCATED
APPROXIMATELY MID'v/AY THROUGH THE CONCRETE SLAB,
- --- - -1'-4'J
1------18'---~
I rr------==--+--+-+--+---,.,------'-1--.-------.-.-----.-r ---,----'jl'l==----=----=---tl=-==-,--fi===il -rr==,
l'~L-.-
6-EB
-
25't
5-Df
DETAIL 6-B
REBAR DET AILS
SCALE 1/2'=1'
--
39'-4'
44'-11'
52'-1'
I I8D 95'
11'-6'
6-
23'-2'I I
D
c
-
L:::L.r
\
SECTION 9-D
SCALE 1°=1'
II I
/~-GRATING SUPPORT ASSY
I
SECTION 8-D
SCALE 1/2"=1'
SECTION 6-D
SCALE 1/2"=1'
\
ANGLE L3X3xl/4
'vi /NELSON STUDS
j 1
IF ;F;~'t'~;Cf,-'8i.;"Y·'fi:"1 ~
-9'-1--'---
1----'---4'---------J
ANGLE L3X3xl/4
'vi /NELSON STUDS
SECTION 5-D
SCALE 1/2'=1'
)1---GRATI G SUPPORT
/
ASSEM LY
SEE D TAIL 9-E
/It----fff---3'-6'k;9-D = = = =---'---
~~I I
I I
-E--- -
6-F
D
c
-
11------26'----I
PLAN 2-F
SCALE 1/8'=1'
34'-8'
F
E
-
-
-=-I1--4"STEEL PIPE
'v/ITH ~"PLATE
DE TAI L 9 - E ***NOTE:HEIGHT OF ANGLE
SCALE 1°=1'SUPPORT IS TO BE FIELD FIT,
1--4'-6'--1
1---------1
ANGLES L3X3~
''---",
8'
SECTION 6-E
SCALE 1/2'=1'
SECTION 6-F
SCALE 1/2'=1'
'----4"HDPE PIPE
1 ~6'----.-----~
10'"t".::~:
.";'..,../:i.~·:'j;----'----
.c.'~"~(~<~::~.-:.;~...:~.~i...:"t .:;:~.;:0..8'
r-3'-10'-----l
I 11
SECTION 5-E
SCALE 1/2'=1'
I I
I 6'
t
5-E r-3'-10'------l
f
1 1
f
l'
I-
/'"",
I I
REBAR DETAILS_-ft---/
6-B
PAD DETAILS _-----'/
5-F
F
E
-
-
AS BUll T DRAwING
SUBMITTED FOR REVIEw
AND APPROVAL
PENISON~~L
MINES
SIGNATURE DATE
DSGN,D'vIG'
SRS 11/12/09
DR'vIN'11/12/09SRS
APPR,RB 11/12/09 SHEET
I 6 I 7 I 8 I 9
-
G
1 I 2 I
DETAIL 5-F
SCALE 1/2°=1'
3 I 4 I 5
**NOTE:HEIGHT OF
FOUNDATION PADS FOR THE
SUPPORT STRUCTURES SHALL
BE VARIED TO ENSURE THAT
THE TOP SURFACES OF ALL
THE PADS ARE THE SAME
ELEVATION,
Title'
2 of
I
7
10
o
SCALE'
-
1
1
2 3
1
4
1
5
1
6
1
7
1
8
1
9
1
10
A -
A
I--
B
t
v ffi
3-Ef
NOTES:
1.SUBGRADE IS TO BE PREPARED LEVEL,
2,SUBGRADE SHALL BE COMPOSED OF COMPACTED SOIL AND ROCK,
3,REINFORCEMENT BAR TO BE USED SHALL BE #6 REBAR,
4,REINFORCEMENT BAR SPACING TO BE 12'ON CENTER VlITH MINIMUM OF 18'
OVERLAP,
5,VlATER STOP TO BE PVC DUMBELL TYPE,
6,REINFORCEMENT BAR TO BE USED SHALL BE #4 REBAR,
7,REINFORCEMENT BAR SPACING TO BE 12'ON CENTER VlITH MINIMUM OF 18'
OVERLAP,
-
B
I---
c
-8-E
~'WATER STOP
8'IPS STAINLESS
STEEL FLANGE &PIPE
-
c
I--
PLAN 3-C
SETTLING TANK DETAILS
SCALE 114'=1'SECTION 8-C
SCALE 114'=1'
-
51'-6·
15'-1·
D -~8'
15'-1·~~,.
24'~10'-1'1 Dl~8'
-8'-8'-~T -6'~~~T T6'-1·5'-6·6'-1·5'-2·®CTYP)I---/-
I j2'
I I
8']
I I
51'-8·16'-8·
E E
SECTION 3-E
SCALE 114'=1'
SECTION 8-E
SCALE 114'=1'
I---
SECTION 6-F
SCALE 1/2'=1'
9 9 9 9 9 9 9 9 9 ,
1 F
------'----8'1-,-------------------------
~-"/------r-'/-'-'-----
~-~
6-FIft
4'
F
I---1------------15'------------1
PLAN 2-G
EQUIPMENT PAD DETAILS
SCALE 112'=1'
OENISOtf)~L
MINES
Title:
-
G
SHEET 3 of 7
SCALE:
1 1 2 3 1 4 1 5 1 9 1 10
1 2 I 3 4 I 5 I 6 I 7 I 8 I 9 I 10
A
B
~3'-6'-1
C6
V~HANDRAIL
C6
6'(TYP)
C6
I---6'(TYP)---l -
P4
,.......-l I ['-6'
NOTES,
1.ALL STRUCTURAL STEEL TO BE ASTM A36 OR EQUIVILANT,
2,ALL TOP AND MIDRAILS TO BE 1-1/2'DIA,SCH 40 STD,PIPE,ASTM A53 OR A106
3,ALL POSTS TO BE 1-112*DIA,SCH 80 STD,PIPE,ASTM A53 OR A106,
4,ALL HANDRAIL JOINTS SHALL BE GROUND SMOOTH,
5,ALL HANDRAIL SURF ACES TO BE SMOOTH AND FREE FROM MILL SCALE,\oIELD
SPLATTER AND OTHER FOREIGN DEBRIS,
6,PLATFORM GRATING TO BE 19-\01-4-1!*xtt;'GALVANIZED,
A
B
c
35'
C6
C6
ELEVATION 5-B
SCALE 114'=1'
['-['~~-+--+['-['
c
112'PLATE 6'X44'
D
E
C6
CIO
-11'
~
5-B
T~3 ~
7'
1~;"r-3'-6'-j
X-SECTION 4-D
SCALE 114'=1'
X-SECTION 5-D
SCALE 114'=1'
X-SECTION 6-D
SCALE 114'=1'
D
E
PLAN 2-E
GRA TING REMOVED FOR CLARITY
SCALE 114'=1'
A
I I
F
JOINT DET AIL 3-F JOINT DET AIL 5-F JOINT DET AIL 6-F JOINT DETAIL 8-F
F
PENISOn~L
MINES
DECDN PAD
PLATFORM DETAILS
LEGEND
C6 C6X10,5
C10 C10x20
G L3 L3XLX1/4
P4 PIPE 4//DIA
SCH 80
1 2 I 3 4 I 5 I
Title'
AS BUll T DRAwING SIGNATURE DATE
SUBMITTED FOR REVIEw DSGN,D\rIG'SRS 11/12/09
DR\rIN'11/12/09ANDAPPROVALSRS
APPR,SHEETRB11/12/09
6 I 7 I 8 I 9
4 of 7
I 10
Rev'Go
SCALE'
1 I 2 3 I 4 I 5 I 6 I 7 I 8 I 9 I 10
~5-F/
A
I---
B
I--
c
I---
D
I--
6-n.u-.----.,
...,
....
I 1'----SETTLING
II TANK
)
I
3'-6""
(\_----.JL
"ffEEEEEEff-"ffEEEEEEEEiQI f'#WEEEEEEEEEEEE~"ffEEEEEEEEff-'EEEEEEEEEEEEEEEEEEff-f'EEEEEEEEEEEEEEEEEE~'EEEEEEEEEE-'EEEEEEEEEEEEEEff-VEEEEEEEEEEEEEff-"ffEEff-
~'-9-F I
(T YP)3'-6'__L
ELEVATION 6-B
SCALE 1/4'=1'
/,----5-F
ELEVATION 6-D
SCALE 1/4'=1'
NOTES:
1.ALL TOP AND MIDRAILS TO BE 1-112/1 DIA,SCH 40 STD,
PIPE,ASTM AS3 OR A106
2,ALL POSTS TO BE 1-112"DIA,SCH 80 STD.PIPE,ASTM
AS3 OR A106,
3,ALL HANDRAIL JOINTS SHALL BE GROUND SMOOTH,
4,ALL HANDRAIL SURF ACES TO BE SMOOTH AND FREE
FROM MILL SCALE,VELD SPLATTER AND OTHER FOREIGN
DEBRIS,
I
l1===#======#====~I==:::OJ 3'-6'
,-------"-----------"'''"-----------''-------,~
I
ELEVATION 6-E
SCALE 1/4'=1'
A
I---
B
I--
c
I---
D
I--
E
I I I I
E16'/119'r-6'I 6'-----l r---r 7'-6'
I
7'-6'----l ~
1"PLATE 1,/"I I
1'-91 1'-91 ~I I
I---I---
F t-- t6 -E
DETAIL 5-F
SCALE 1/4'=1'
DETAIL 7-F
SCALE 1/4'=1'DETAIL 9-F
SCALE N/A F
I--PLAN 2-F PENISON~~L I--
SCALE 1/4'=1'
MINES
Title:AS BUll T DRAwING DECDN PAD
SUBMITTED FOR REVIEw SIGNATURE DATE HANDRAIL DETAILS
G DSGN:D\.,IG:Rev:G
AND APPROVAL SRS 11/12/09 0
DR'v/N:11/12/09SRS SCALE:
APPR:RB 11/12/09 SHEET 5 of 7
1 I 2 3 I 4 I 5 I 6 I 7 I 8 I 9 I 10
1 2 3 4 5 6 7 8 9 10
F
A
B
c
E
D
SCALE:
10
<
<
'------INTERIOR CONCR TE
DIVIDER VIALL
'------STEEL LINER
7
VIALL
)<-,L-;f-OPEN CAVITY EXTENDS
TO CONCRETE FLOOR FOR
LEAK INSPECTION
~-STEEL LINER
of
~-PIPE CAP
~-3'¢STEEL PIPE
w/NPT THREADS
..0 <1...4 ..A".
"<I.4
<.<
6
.<
<
ENISOJ)~
MINES
DETAIL 9-F
OBSERVATION PORT
SCALE N/A
.~.<.
4
<.
DETAIL 9-D
OBSERVATION PORT
SCALE N/A
.<
EL 5589,8
f
4'(TYP)
Ll ..<.
<
~~~.<~'--TAN
4 4 .
.<
Title:
EXTERIOR CONCRETE
VIALL
-r---LINER
----PIPE
11'
4
NOTES:
1.STEEL LINER IS TO FDLLO\v'THE CONTOUR OF THE CONCRETE TANK
STRUCTURE AND COVER THE FULL INTERIOR OF THE CONCRETE TANK
SUCH AS TO SEAL THE CONTENTS INSIDE THE LINER FROM THE
CONCRETE TANK STRUCTURE,THE LINER SHALL \v'RAP OVER THE
OUTSIDE EDGES AND EXTEND DO\v'N THE OUTSIDE EDGE OF THE TANK
APPROXIMATEL Y 6"AS SHO\v'N,
2,LINER IS TO BE MADE OF CARBON STEEL \v'ITH A MIN THICKNESS OF
~"ON THE BOTTOM OF THE TANK AND ~"ON THE SIDES,
3,ALL JOINTS ON THE LINER ARE TO BE 100%\v'ELDED SO AS TO
PREVENT LEAKAGE,
4,THE OBSERVATION PORTS SHALL BE OPEN FROM THE TOP OF THE
TANK DO\v'N TO THE CONCRETE FLOOR OF THE TANK SUCH THAT A
LEAK IN THE LINER \v'OULD BE DETECTED AS EARLY AS POSSIBLE,
DETAIL 8-G
PIPE PENETRATION
PUMP SUCTION
SCALE N/A
SIGNATURE DATE
DSGN:DVlG:
SRS 11/12/09
DRVlN:11/12/09SRS
APPR:RB 11/12/09 SHEET
7 8 9
-r---GEDNET DRAINAGE LAYER
APPRO X il'THICK
~-CONCRETE TANK STRUCTURE
~-STEEL LINER
"'!'.4'
•
6
DETAIL 6-G
TANK FLOOR
SCALE N/A
4"....;"'4 :
<l~...~..:.~."/>
.....<1.,(I.".
...<I i ..
..,..<I".,.<I""4 .~
...~...."",.<f...<I .
•.."."..:1 .<I .~:"<I ...<I~...:.a.,."..,..".
ELEVATION 6-[
SCALE 114'=1'
ELEVATION 6-E
SCALE 1/4'=1'
54
ELEVATION 4-G
SCALE 1/4'=1'
32
PLAN 2-F
SCALE 114'=1'
AS BUll T DRAwING
SUBMITTED FOR REVIEw
AND APPROVAL
9-F
1
F
A
B
c
G
D
E
1 2 3 4 5 6 7 8 9 10
A
B
c
D
E
,-----DETAIL 8-C
'----SADDLE
ANCHOR BOTH SIDES
~\v'4X13
!~-L2X2X1I4'
ELEVA TION 9-E
SPRAY SHIELDING
SCALE 118'=1'
T
7'
~
DETAIL 8-[
SPRAY SHIELDING
SCALE N/A
NOTES:
1.SPRAY SHIELDING TO BE ALONG THE FULL LENGTH OF THE DECON
PAD ON BOTH SIDES,
2,SPRAY SHIELD SUPPORTS SHOULD BE SPACED A MAXIMUM DISTANCE
OF 10 'APART,
3,SIDING IS TO HANG BELO\v THE CONCRETE EDGE SO AS TO PREVENT
\VATER FROM RUNNING OUTSIDE OF THE DECON PAD,
4,BRACKETS ARE CUSTOM FABRIC ATION AND SHALL BE SIZED TO HOLD
THE MEMBERS THEY ARE SUPPORTING,
CORRUGATED METAL SIDING ~
SEE NOTE 3 "
\v'4X13
SEE NOTE 1
~
'"I I I I
~
I I I I
I I I I
I I I I
I
'3-Ef
,
SIDE
BOTTOM
ELEVATION
TOPlCUSTOM r
[J ZZ ZZ ZZ ZZ :11
DETAIL 4-[
BRACKET
SCALE N/A
4'-3"
·.~<r·;",."
:";~~.~
.?i:~:~..',:;,/;
:~.~:~~:!j;;:>
\v'4X13
ELEVATION 2-B
HEAT EXCHANGER PLATFORM
SCALE 3/8'=1'
~-PLATFORM GRATING
A
B
c
D
E
F PLAN 2-F
HEAT EXCHANGER PLATFORM
GRA TING REMOVED
SCALE 3/8"=1'
PLAN 6-F
SPRAY SHIELDING
SCALE 118'=1'
F
ENISOJ)~
MINES
AS BUll T DRA wING
SUBMITTED FOR REVIEw
AND APPROVAL
SIGNATURE DATE GDSGN,D\v'G'Rev'
SRS 11/12/09 0
DR\v'N'SRS 11/12/09 SCALE'
APPR,RB SHEET 7 of 711/12/09
8 9 10
G
1 2 3 4 5 6 7
Title'DECDN PAD
HEAT EXCHANGER PLATFORM
~SPRAY SHIELDING
Attachment E
OENISO
MINES
Oenl,on Mines Corp.
6425 S.Highw/lY 191.PO BoJ:809
Olandlng,UT 84511
USA
Tel:435 67&-2221
FA :4351J71-2224
w_.denllonmlnes.com
TESTING PROCEDURE -LEAK CHECK NEW OeCON COLLECTION TANK LINER
The following is the procedure to ensure that the steel tank liner that has been installed In the collection tank
does not have any leaks prior 10 entering into service.The collection tank has three bays with an inspection
port in the comer of each bay.These ports are covered by a pipe cap.It is critical that Ihese caps be left in
place at all times except at time of inspection and measurement.Prior 10 testing il has been confirmed that
there is no water inside these inspection ports.Prior 10 starting testing this water must be removed to aU
reasonable extent.The test period shall be 48 hours.The following procedure shall be completed and dates,
times,and signatures filied in.The completed form shall be returned to Steve Snyder.
1.Verify that each bay has had the residual water removed.Initial d
a.Bay 1 (South Bay)
b.Bay2 (Middle Bay)
c.Bay3 (North Bay)
a.Bay 1 (South Bay)
b.Bay 2 (Middle Bay)
c.Bay 3 (North Bay)
a.Bay 1 (South Bay)
b.Bay 2 (Middle Bay)
c.Bay 3 (North Bay)
2.Establish Baseline·Measure any water level in each bay and record along with the Date and Time of
Measurement.
Waler Level (J (p,,)Date u'l/Itl Time 11:170 q""
Water Leve~Date z:1'l!lfJ Time fl:Of)Q'"
Water Level~Date 7:/rr/;P Time II:PO q~
Initial .B
3.2nd Measurement (24 hrs)-Measure water level in each bay and record along wilh the Dale and Time
of Measurement.
WaterLevel~;ODale Zlttlf()nne b:fJDa"i
Waler Level O{()~Dale ~UP nme U:~6 .~
Water Level ()1",Dale wi//f?Time !f.-OPt),..
Initial :ill
4.Final Measurement (48 hrs)-Measure water level in each bay and record along with the Date and
Time of Measurement.
Waler Level-;f1 Dale 7/u,ltll Time ;:llP1'"
Water Level ()/lit Date WIU Time I"~pm
Waler Level a.Dale 7/tW Time I.'PIt?""
Initial gq:
A passing lesl will show no measurable increase in waler level.Afailed test shall resultln leak.repair and
retesting.
Pass or Fail A<1 Signalure -!ZC-?<-,L~Dale j,~~~~S
Attachment F